On May 12, 2016, at 5:56 PM, David Huberman <[email protected]<mailto:[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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