[arin-ppml] Policy Proposal 105: Simplified M&A transfer policy

Owen DeLong owen at delong.com
Tue Dec 22 20:22:45 EST 2009


On Dec 22, 2009, at 5:11 PM, Joe Maimon wrote:

> 
> 
> Owen DeLong wrote:
>> 
>> On Dec 22, 2009, at 3:00 PM, Joe Maimon wrote:
>>> 
>>> I think that bringing the possibility of renumbering and reclamation is somewhat of a disincentive to getting people into the door in the first place. If you are buying a network that you may have to renumber, you might want to think twice about it - or wait until you finish renumbering it before going to 8.3.
>>> 
>> I don't see the connection, necessarily.
>> 
>>> What is the priority for the goals of 8.2 and how much efficiency should we let slide to achieve them?
>>> 
>> Primarily to make it clear that number resources are not transferable away from their original intended
>> purpose without justified need under ARIN policy.  8.3 is not particularly useful for the merger/acquisition
>> of company scenario.
>> 
>> Both policies preserve the same requirement that you adhere to ARIN needs-based policy
>> to effectuate a legitimate transfer.
>> 
>> Owen
>> 
> 
> Lets take this illustration. Suppose I acquire an ISP whose bread and butter is dialup and some colo servers. They justified a /20 when they started out, but their dial up population has been decreasing steadily. They would only qualify now for a /22. Thats not an issue for them since they are not trying to obtain any more space.
> 
Sure it is... A section 12 resource review could well cause them to need to return some of that space.
They should return it if they are no longer using it.

> Does this policy change increase or decrease the odds that I would choose to initiate 8.2 rather than simply continue to treat these resources and organizations as separate ARIN entities? And if acquiring this company initates a review of my companies utilization, does the acquisition now have higher risk because of these policy changes?
> 
Not really... The company could get reviewed at any time under section 12 whether you acquire it or not.

> Do we want organizations to voluntary initiate 8.2? Renumbering a legacy network where everything works just fine as it is adds to acquisition costs.
> 
Again, this doesn't require any renumbering that wouldn't otherwise be required under ARIN policy. It does
make it more likely that policy could get enforced, but, other forces will drive that absent acquisition in the
near future in my opinion.

> And if the likely result of any of this policy change means that you are going to have to renumber, it is probably better to just go ahead and do so. Hold off on 8.2 and wait for depletion so that you can either 8.3 between organizations or just to get some dollars.
> 
I don't think that the policy change being proposed change that likelihood vs. the current policy.  Both existing
and the proposed change to the policy provide for a review.

So does section 8.3.

Owen




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