[arin-ppml] ARIN-prop-173 Revisions to M&A TransferRequirements(Updated Version)

David Farmer farmer at umn.edu
Thu Jul 5 19:05:47 EDT 2012

On 7/5/12 17:28 CDT, Michael Sinatra wrote:
> On 07/05/12 15:24, David Farmer wrote:
>> On 7/5/12 17:17 CDT, Michael Sinatra wrote:
>>> On 07/05/12 13:31, sandrabrown at ipv4marketgroup.com wrote:
>>>> At present, I don't think they will come forward, and risk being
>>>> told to
>>>> aggregate internally generating tons of engineering and operational
>>>> work, and thus, the ARIN database would remain out of date.
>>> To the extent that this proposal exempts M&A transfers from any
>>> renumbering requirement (or even encouragement), it introduces a
>>> double-standard into the NRPM. As an example, section requires
>>> small multihomers (I love that word!) to renumber upon getting
>>> additional assignments. Note the opposition on this mailing list to
>>> proposal 167, which would have mitigated that requirement. While not
>>> expressing an opinion as to who should "have to" renumber, I do not
>>> think the NRPM should have the effect, intended or otherwise, of placing
>>> greater renumbering onus on small entities versus large ones. If we're
>>> concerned about routing table bloat from the mom-and-pops, then we
>>> should be concerned about it from M&A transfers, regardless of the size
>>> of the merger or acquisition. Likewise, if it was "too hard" for a
>>> Nortel to consider renumbering, why is it so much easier for a
>>> mom-and-pop to renumber? Mom-and-pops don't have to renumber as much,
>>> but they don't have the same resources at their disposal to throw at the
>>> renumbering task.
>> I'm missing something here, how does renumbering apply to this
>> discussion?
> Paragraph 2 of section 8.2:
> "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, ARIN will work
> with the resource holder(s) to return, *aggregate,* transfer, or reclaim
> resources as needed to restore compliance via the processes outlined in
> current ARIN policy."
> Sandra appeared to be responding to the possibility that ARIN would
> request that M&A transfers result in the aggregation (i.e. renumbering)
> of resources, which she considers onerous: "isk being told to aggregate
> internally generating tons of engineering and operational work."


I agree that it shouldn't matter how big you are If you need to 
aggregate or renumber you need to do it.  However, big or small, legacy 
or not, why should you have to aggregate and return addresses because 
you change the name of the organization? Why should that event trigger 

If a mom and pop organization changes its name they should be able to 
update the records with the new name without having to rejustify their 
use, its not about size.  If they we justified under the old name why 
shouldn't they be justified under the new name?  The use didn't change 
by changing the name.

If you are changing the use by transferring the number resource 
independently then yes you need to rejustify the use, that is what 8.3 
is about.  But, why for a name change, that seems like a high bar for 
something that trivial.

I don't agree with most of the rest what she said, but on this issue I 
agree It creates a disincentive for updating the registry.

David Farmer               Email:farmer at umn.edu
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