[ppml] Policy Proposal: Transfer Policy Clarifications

[michael.dillon at bt.com]

> 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:
> 
> * Existing customer base
> * Qualified hardware inventory
> * Specific software requirements

Very strange list. If the buyer takes over the functioning network, or
the components of the functioning network such as "circuit contracts"
and PoPs, then it is clear that they justify the addresses. But this is
missing from the proposed policy.  

On the other hand, if they are gutting the acquisition and supply a
customer list and an autioneer's list of routers, switches, and servers,
this somehow justifies keeping the addresses?

Of course the current policy is just as broken, but if you are going to
fix this section, why not really fix it. This policy gets too deep into
details that don't need to be in policy. The fact is, that the new owner
has to justify their use of addresses on the same basis as any new
applicant. If policy needs to have any details of what justifies
addresses then it should be listed in one place and that should not be
in the "transfer" section. 

Also, policy cannot override the law. If an org changes its name or
becomes a wholly owned subsidiary, the transfer should be as simple as
changing the org template. If the org is dismantling its network, then
that is a situation where policy should call for an audit or refer to
the requirements for RECEIVING an allocation.

I'm all for fixing the "number resources" confusion but I think this
section of policy has stuff which doesn't belong there.

--Michael Dillon