Apologies in advance for jumping in at the last minute on a policy that's in recommended form, but I have a few questions and observations.
1) The problem statement says: > First, it often takes longer than 30 days to stage equipment and start actually using the addresses. Earlier on, Jason says: > "I know I worked very hard to get my recent end-user assignment over 25% by the deadline." It is my understanding, Jason, that you're a proponent of some form of verification with teeth - presumably something more aggressive than the 1 year/50% that would still be included if 2015-3 passes muster, but you also concede that you had a difficult time meeting the current 30 day "deadline." I could be completely off base because I haven't been following 2015-3 since its inception, but has there been any discussion of a test that sits somewhere between 25%/30 days and 50%/1 year? 2) It seems 4.3.3 in its current incarnation *doesn't have teeth to begin with *as it applies to transfers (which are really the only option in a post-depletion world.) John Curran says: 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.”* [emphasis my own] My understanding from these comments is that ARIN has not been doing 30 day check ups on transfers because *staff has not received direction on how to apply the existing policy to transfers, *which would be the reason behind the staff assessment, "This policy would more closely align with the way staff applies existing policy." To that end, then, the policy in its current incarnation is not completely obsolete as some folks have claimed on the PPML. Staff simply don't have direction for application of the utilization rates. It seems there needs to be clearer consensus around what the action of ARIN staff ought to be a) in pursuing verification in the first place re: transfers and b) in cases where verification tests aren't met. Should ARIN be automatically checking in at the 30 day or 1 year mark? If so, what does ARIN do if the 25%/30 days or 50%/1year tests aren't met? Should ARIN revoke the address space? Serve the offender notice? Are either of these ethical in a post-depletion world where folks have paid for address space? If the community is to give direction in these areas, should it be included in 2015-3, or in a separate problem statement? Feel free to set me straight on all of this 'cause I'm a giant nooooob. - Alyssa On Fri, May 13, 2016 at 4:19 PM John Curran <[email protected]> wrote: > On May 13, 2016, at 3:38 PM, Jason Schiller <[email protected]> wrote: > > > I am highly confused now. > > We have the 25% utilization check which really is the only verifiable > check to rate-limit aggressively optimistic requests. > > On one hand, ARIN does not check this figure. As such the policy > change is a no-op. > > On the other hand the 25% utilization goal remains part of the > policy and having no intention of complying is fraud. > > ARIN could make random checks, or check all of them. > > ... > > > Jason - > > Are you referring to assignments or transfers? The above discussion > appears to mix requests of both types. > > ARIN does check that end-user _assignment_ requests meet the > 25% immediate utilization requirement (as called for in the end-user > assignment policy.) > > ARIN does not have clear guidance how the assignment criteria for > 25% immediate use is to be applied to transfers. ARIN can apply the > criteria with respect to transfer requests, but that would require some > additional policy clarity from the community to do so. > > So in that respect the policy change is not a no-op. > > > The policy change will not materially affected transfer requests, as > noted > above. The change would effect processing of any end-user assignments > requests. (It is probably worth noting that end-users who presently > qualify > for assignment of an IPv4 block are being added to a waiting list with > a > rather low probability of timely fulfillment.) > > Thanks, > /John > > John Curran > President and CEO > ARIN > > > > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues.
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