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

Scott Leibrand scottleibrand at gmail.com
Tue Dec 22 20:34:47 EST 2009

On 12/22/2009 5:11 PM, Joe Maimon wrote:
> Lets take this illustration. Suppose I acquire an ISP whose bread and 
> butter is dialup and some colo servers. They justified a /20 when they 
> started out, but their dial up population has been decreasing 
> steadily. They would only qualify now for a /22. Thats not an issue 
> for them since they are not trying to obtain any more space.

Ok.  So the dialup pools are dynamically assigned, and the colo servers 
are static.  Under NRPM section 12, the ISP you acquired was already 
subject (before the acquisition) to an audit of their space.  Assuming 
they no longer need all of it, they would be asked to return some of 
it.  That *doesn't* mean they'd need to do any renumbering.  Per 4.6.2 
and especially 4.6.3, "An organization shall be allowed to return a 
partial block of any size to ARIN. For any return greater than a /24, 
ARIN shall not require that the non-returned portion of the block be 
renumbered unless the returning organization wishes to do so."  So they 
could simply return half of their dynamic dial-up pool.

> Does this policy change increase or decrease the odds that I would 
> choose to initiate 8.2 rather than simply continue to treat these 
> resources and organizations as separate ARIN entities? And if 
> acquiring this company initates a review of my companies utilization, 
> does the acquisition now have higher risk because of these policy 
> changes?
> Do we want organizations to voluntary initiate 8.2? Renumbering a 
> legacy network where everything works just fine as it is adds to 
> acquisition costs.

Several different scenarios are possible:

  - Let's say you're growing your business, and have been requesting a 
/23 every six months.  Therefore, you'll be able to use the extra /22 
within a year, and you shouldn't have to return anything.
  - Alternately, let's say you're also in the dial-up business, and have 
some unused space of your own.  In that case, you'd need to return some 
space.  As I mentioned above, that doesn't require you to renumber if 
you don't want to: you can just return the unused space.

> And if the likely result of any of this policy change means that you 
> are going to have to renumber, it is probably better to just go ahead 
> and do so. Hold off on 8.2 and wait for depletion so that you can 
> either 8.3 between organizations or just to get some dollars.

You can already use 8.3 to transfer IPv4 addresses between 
organizations, but the receiving organization has to have a justified 
need for the space.

If an organization is attempting to defraud ARIN by hanging on to 
unjustified IPv4 space until scarcity develops, with the intent of 
attempting to transferring that space under 8.3 for a profit, then no 
matter what we do to 8.2, they're going to do their best to stay as far 
away from ARIN as possible until they're ready to transfer the space.  I 
actually attempted to address that, to some degree, by directing ARIN to 
"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" "in the event that number resources of the combined 
organizations are no longer justified under ARIN policy at the time ARIN 
becomes aware of the transaction, through a transfer request or 
otherwise".  That way the resource review will occur as soon as ARIN 
finds out about the situation, regardless of whether a transfer request 
is initiated.


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