[ppml] Policy Proposal 2007-8: Transfer Policy Clarifications

Edward Lewis Ed.Lewis at neustar.biz
Thu Apr 26 10:58:00 EDT 2007


Perhaps it is a bit late to respond to this, but I didn't get to see 
mail until this morning.  And I think that what I am about to say 
here is something I already expressed at the mic earlier in the week.

The case I am concerned with is number resources "issued" without a 
registration service agreement in place, more concretely and 
colloquially described as legacy space or "space gotten from Postel." 
But I suppose that is a matter for another would-be policy proposal.

At 18:29 -0400 4/22/07, Azinger, Marla wrote:
>Ed and All-  I'm a little behind getting my response out, sorry.  I 
>think your concerns about wording should be looked at.  Hopfully I'm 
>not missing some postings to this that already resolved your 
>concerns.  If there are...just ignore this email. ;o)
>
>I worked on some rewrites of the text you are concerned about.  I 
>thought it might be good to have some rewritten text suggestions put 
>out to everyone so that if we decide we dont like how it is 
>currrently written, we can already start looking at another way of 
>saying "what we mean".  So here are my suggestions to the parts that 
>may need some rewriting.
>
>1. Current proposal verbage:
>"It should be understood that number resources are not "sold" under ARIN
>administration. Rather, number resources are assigned to an organization
>for its exclusive use for the purpose stated in the request, provided
>the terms of the Registration Services Agreement continue to be met and
>the stated purpose for the number resources remains the same. Number
>resources are administered and assigned according to ARIN's published
>policies."
>
>Suggested Rewrite:
>Number Resources are managed as a finite resource and not as a 
>commodity.  Number resources are assigned or allocated to an 
>organization for its exclusive use for the purpose stated in the 
>request, provided the terms of the registration services agreement 
>continue to be met and the stated purpose for the Number Resources 
>remains the same.  Number Resources are to be managed in accordance 
>with ARIN's Published Policies.
>
>
>2. Current proposal verbage:
>"Number resources are issued, based on justified need, to organizations,
>not to individuals representing those organizations. Thus, if a company
>goes out of business, regardless of the reason, the point of contact
>(POC) listed for the number resource does not have the authority to
>sell, transfer, assign, or give the number resource to any other person
>or organization. The POC must notify ARIN if a business fails so the
>assigned number resources can be returned to the available pool of
>number resources if a transfer is not requested and justified."
>
>Suggested Rewrite:
>Under the circumstance of an organization closure where said 
>organization has Number Resources from ARIN, said organization must 
>notify ARIN to either return the Number Resources to ARIN or 
>transfer the Number Resources in accordance with ARIN Policy 
>(reference section 8.2 and 8.3).
>
>
>Cheers!
>Marla
>-----Original Message-----
>From: ppml-bounces at arin.net [mailto:ppml-bounces at arin.net]On Behalf Of
>Edward Lewis
>Sent: Monday, March 05, 2007 7:55 PM
>To: ppml at arin.net
>Cc: ed.lewis at neustar.biz
>Subject: Re: [ppml] Policy Proposal 2007-8: Transfer Policy
>Clarifications
>
>
>At 12:15 -0500 3/2/07, Member Services wrote:
>
>>http://www.arin.net/policy/proposals/2007_8.html
>
>>Policy Proposal 2007-8: Transfer Policy Clarifications
>>
>>Author: Paul Andersen
>>
>>Proposal Version: 1.0
>>
>
>>It should be understood that number resources are not "sold" under ARIN
>>administration. Rather, number resources are assigned to an organization
>
>What I find a bit confusing is the difference between the thought
>that ARIN "leases" resources versus the thought that a company might
>"sell" resources from one to another.
>
>(An off-shoot of this comes from the fee discussion in APNIC, where
>resources whose registration is static see the per-year fees
>decrease.  This reflects the nature of the activity as that of
>managing a registry and not as a "LAN-lord.")
>
>...
>>not to individuals representing those organizations. Thus, if a company
>>goes out of business, regardless of the reason, the point of contact
>>(POC) listed for the number resource does not have the authority to
>>sell, transfer, assign, or give the number resource to any other person
>>or organization. The POC must notify ARIN if a business fails so the
>>assigned number resources can be returned to the available pool of
>>number resources if a transfer is not requested and justified.
>
>What exactly does "going out of business" mean?  A company can be
>absorbed by another through a purchase and the brand name tossed away
>while still maintaining the need for the resources.
>
>In a way I can see this saying the transfers can never happen,
>meaning that if I buy someone's hosting service I may have to apply
>for new addresses.  Worse is the thought that I'd have to renumber if
>I don't get the transfer of resources.
>
>I'm asking an obtuse question because the text doesn't say which
>POC(s) is/are involved.  What if the POC is a role account that
>transfers with the rest of a once independent company?
>
>>8.2 Transfer Requirements
>>
>>ARIN will consider requests for the transfer of number resources only
>>upon receipt of evidence that the new entity has acquired the assets
>>which had, as of the date of the acquisition or proposed reorganization,
>>justified the current entity's use of the number resource. Examples of
>>assets that justify use of the number resource include, but are not
>>limited to:
>
>I pretty much agree with the intent of this proposal...it's the words
>I am quibbling about in the previous section.
>
>>Rationale:
>>
>>Staff analysis and community comments have a problem with the
>>inconsistent use of the terms "ASN" and "IP Address" in this section
>>which leads to confusion on which resources can be transferred. The
>>entire section now utilizes the term "number resources" to clarify what
>>would appear to be the original intent.
>
>I have come across people that find the ARIN on-web flow-chart
>confusing because AS numbers are not included in the prose.  And I
>have been told that the prose comes from the policy.  So I'll add a
>data point saying that this is in need or updating.
>
>--
>-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-
>Edward Lewis                                                +1-571-434-5468
>NeuStar
>
>Sarcasm doesn't scale.
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-- 
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Edward Lewis                                                +1-571-434-5468
NeuStar

Sarcasm doesn't scale.



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