[arin-ppml] Policy Proposal 105: Simplified M&A transfer policy
owen at delong.com
Tue Dec 22 18:22:47 EST 2009
On Dec 22, 2009, at 3:00 PM, Joe Maimon wrote:
> Owen DeLong wrote:
>>> In the event that number resources of the acquired/merged
>>> organization(s) are no longer efficiently utilized at the time ARIN
>>> becomes aware of the transaction, through a transfer request or
>>> otherwise, ARIN will work with the resource holder(s) to return or
>>> aggregate resources as appropriate via the processes outlined in
>>> sections 4.6, 4.7, or 12 of the NRPM.
>> I think that there's an issue here. I think that we need to talk about
>> the number resources of the resultant combined organization rather
>> than of the acquired/merged organization... Here's why...
>> The term acquired/merged could be construed to refer only to the
>> resources that were acquired without regard for the resources already
>> held by the acquiring organization. Let's say that two organizations
>> A and B merge. Prior to merger, A efficiently used 17 /24s and held
>> a /19, while B efficiently used a /23 and held a /22. The combined
>> usage is 19 /24s which would justify a /19, but, would not justify the
>> /22 of additional space. The /22 should be returned in this case and
>> be renumbered into the /19.
> 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.
> These changes could make 8.3 more attractive than 8.2
As a point of information, I am proposing changes to a proposal to bring its effect closer to
existing policy, not changes to the implementation of existing policy.
Since this proposal is billed as a "simplified" M&A transfer policy and intended, as I understand it
to provide a clearer wording for essentially current policy effect, I think that is desirable. I do not
think that relaxing efficiency requirements is desirable for 8.2.
Further, 8.3 is not a substitute for 8.2, since, 8.3 would require the acquiring organization to
completely justify their need for all the space coming from the organization to be acquired
without using the network assets/utilization of the organization being acquired.
Both policies preserve the same requirement that you adhere to ARIN needs-based policy
to effectuate a legitimate transfer.
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