[arin-ppml] Policy Proposal 105: Simplified M&A transfer policy
scottleibrand at gmail.com
Tue Dec 22 17:49:34 EST 2009
On 12/22/2009 2:17 PM, Owen DeLong wrote:
>> 8.2. Mergers and Acquisitions
>> ARIN will consider requests for the transfer of number resources in the
>> case of properly documented mergers and acquisitions. ARIN will
>> maintain an up-to-date list of acceptable types of documentation.
> Perhaps ...ARIN staff will...
IMO just "ARIN" is better than "ARIN staff". We don't want to dictate
how ARIN does it. If ARIN decides that the best way to maintain an
up-to-date list of acceptable types of documentation is to pay a
contractor to do it, that's fine. It doesn't have to be staff's job, it
just has to be done.
>> 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.
Fair enough. Should I just change it to read "In the event that number
resources of the combined
organizations are no longer efficiently utilized..."?
>> Add "In addition to transfers under section 8.2, " at the beginning of
>> section 8.3. Transfers to Specified Recipients.
> Otherwise, looks good to me.
>> This policy proposal: attempts to simplify the M&A transfer section of
>> the NRPM; eliminates the ambiguity discussed at the ARIN Public Policy
>> Meeting (PPM) in Dearborn by clarifying that transfers can occur under
>> either 8.2 or 8.3 independently; and attempts to address the concerns
>> raised in the staff policy implementation report at the Dearborn PPM.
>> The idea here is to simply say that ARIN will allow M&A transfers, and
>> to require the return of any address space that is not efficiently
>> utilized after the acquisition. Preferably that would happen
>> voluntarily under the policies of NRPM 4.6 (Amnesty), but it also leaves
>> the door open for ARIN to revoke space under NRPM 12 (Resource Review)
>> if necessary. This also should dramatically increase the completion
>> rate for transfer requests, as the evaluation of whether space is
>> efficiently utilized after the transfer can occur in parallel,
>> completely independently of the transfer request, and can continue even
>> if the transfer request is abandoned.
>> The bulleted lists of acceptable documentation removed from the NRPM
>> should be maintained by ARIN elsewhere on the website, such as at
>> Timetable for implementation: Immediate
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