On Jul 23, 2014, at 8:28 PM, Scott Leibrand <scottleibr...@gmail.com> wrote:

> Ok, I think I understand what you're concerned about.  But I think that's a 
> different issue, which isn't caused by a conflict with the NRPM, but rather 
> is caused by ARIN's operational practice (correct me if I'm wrong, John) of 
> requiring 50% utilization of acquired space to complete an 8.2 transfer.  
> Maybe it would be useful if ARIN staff could detail what the operational 
> practice is in the case of an 8.2 transfer request of dramatically 
> underutilized space?

Scott -

If the combined resources of an NRPM 8.2 transfer appear less than 50% 
utilized, we ask for their 
3, 6 and 12 month projections and as long as they show projected usage of at 
least 50% of the 
block within one year, we approve the transfer.  If they don't project at least 
50% utilization within 
one year, we work with them to return or transfer space to come into compliance.

We use the 50% utilization criteria which is presently documented in the end 
user policy, as that 
is the most generous interpretation of the NRPM 8.2 language (i.e. "justified 
under ARIN policy") 
available.  Adoption of ARIN-2014-9 as written would not change this practice, 
only make clear 
that we are not reclaiming blocks in this situation.

Thanks!
/John

John Curran
President and CEO
ARIN



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