Thank you John.

I reiterate my last post.  The criterion is obsolete and this recommended draft 
policy should proceed through PDP.

> On May 12, 2016, at 6:37 PM, John Curran <[email protected]> wrote:
> 
>> On May 12, 2016, at 5:56 PM, David Huberman <[email protected]> wrote:
>> 
>> John,
>> 
>> 1) how many 8.3 transfers have been approved as of 30 April 2016?
> 
> Do you mean transfers since IPv4 transfer policy inception, or simply in 2015?
> (They are all listed here:  
> https://www.arin.net/knowledge/statistics/transfers.html)
> 
>> 2) of those, how many were reviewed and verified with the explicit 
>> requirement that 25% of the requested space to be transferred-in would be 
>> used immediately?
> 
> Such a requirement could only be applicable transfers to end-users who were 
> demonstrating 
> their 24-month need using NRPM 4.3.3, and there is no clear interpretation 
> for application of
> the  "25% immediate utilization rate” language.   As such, it is not directly 
> considered during
> the process (as elaborated by Richard Jimmerson on the list); therefore none 
> were “reviewed
> and verified explicitly” for that purpose.
> 
> Note that the language remains applicable (and organizations that attempt to 
> transfer without
> having immediate utilization do run the risk of number resource fraud), but 
> is not integrated 
> into the end-user transfer review process as its extrapolation into that 
> context is unclear.  
> This is also why the staff and legal review for draft policy 2015-3 notes - 
> "This policy would 
> more closely align with the way staff applies the existing policy in relation 
> to 8.3 transfers.”
> 
> Thanks!
> /John
> 
> John Curran
> President and CEO
> ARIN
> 
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