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

Scott Leibrand scottleibrand at gmail.com
Tue Dec 22 18:41:57 EST 2009

On 12/22/2009 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.
> What is the priority for the goals of 8.2 and how much efficiency 
> should we let slide to achieve them?
> These changes could make 8.3 more attractive than 8.2

8.3. is already significantly more attractive than 8.2 in many cases for 
simply transferring IPv4 resources, but 8.3 doesn't apply to IPv6 or ASN 
resources.  The current NRPM's 8.2 
(https://www.arin.net/policy/nrpm.html#eight2) is much more complex, and 
basically requires "that the assets being transferred  (e.g. customers 
or equipment) must have been using the resources at the time of the M&A" 
page 9).  The new proposal simply says that, if you're not using the 
space and don't have a need for it in the near term (which I'd assume 
would mean 12 months, since that's how much space you can currently 
request), then you need to work with ARIN to return unused resources.  
As you can see from the policy_exp_report.pdf, that much more closely 
matches actual current practice, and ARIN staff's recommendation for 
revising the policy to match the actual needs of transfer applicants.

I'm not sure I understand your point about renumbering.  No one making 
an acquisition is forced by ARIN to renumber.  If they wish to renumber 
and return space, then NRPM 4.6 allows them "an appropriate timeframe" 
of 6-18 months (with a possible extension of 6-12 months more), and NRPM 
4.7 allows 12 months for renumbering to aggregate space.

Do you feel that the proposal's simplified 8.2 language is in any way 
worse than the version it would replace?  Do you have any suggestions 
for how to improve it?


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