[arin-ppml] REVISED: Draft Policy ARIN-2012-8: Aligning 8.2 and 8.3 Transfer Policy
JOHN at egh.com
Mon Nov 19 15:13:33 EST 2012
On Mon, 19 Nov 2012, Chris Grundemann wrote:
> Thanks for the feedback Owen.
> On Mon, Nov 19, 2012 at 12:26 PM, Owen DeLong <owen at delong.com> wrote:
> > 1. first bullet, s/used/use/ in that the acquired assets should still be using the resources in order to justify an M&A transfer.
> That would constitute a change from the existing text, which several
> folks spoke against at the PPM. I'd like to get more feedback before
> changing it back again. Comments from others in the community would be
> very much appreciated.
Would this effect the case where an organization in financial difficulty
has ceased operations (and so isn't currently using any of the assets),
but the acquiring org is planning to resume operations? Seems to me we
should want to encourage that, rather than encouraging fire sales in
this kind of situation. Maybe adding " and intends to continue or resume
such use" to the first sentence. Or would that constrain the recipient
> > 2. Third bullet should read "current and future ARIN policies".
> Good catch, thanks.
> > 3. Suggest updating the minimum transfer size specification to reflect "Current ARIN minimum allocation or assignment policy as defined in section 4 or section 6 or the original assignment size, whichever is smaller." since over time we have seen change
> s in these minimums and I would prefer that the transfer policy automatically track other policy changes.
> I believe that would effectively allow everyone to transfer v4/28s
> today based on 4.10 - is this something the community wants to allow?
> More feedback in this area would also be helpful.
> > Owen
> > Sent from my iPad
> > On Nov 19, 2012, at 9:55 AM, Chris Grundemann <cgrundemann at gmail.com> wrote:
> >> Hail PPML,
> >> Following discussion at the 30th ARIN PPM, ARIN-2012-8 has been
> >> revised. A change-log has been added to the rationale. Please send
> >> feedback at your earliest convenience.
> >> ----8<----8<----8<----
> >> Draft Policy ARIN-2012-8 Aligning 8.2 and 8.3 Transfer Policy
> >> Date: 19 November 2012
> >> Policy statement:
> >> Replace the first paragraph of section 8.2 with the following (second
> >> paragraph remains unchanged):
> >> ARIN will consider requests for the transfer of number resources in
> >> the case of mergers and acquisitions under the following conditions:
> >> * The new entity must provide evidence that they have acquired assets
> >> that used the resources transferred from the current registrant. ARIN
> >> will maintain an up-to-date list of acceptable types of documentation.
> >> * The current registrant must not be involved in any dispute as to
> >> the status of the transferred resources.
> >> * The new entity must sign an RSA covering all transferred resources.
> >> * The transferred resources will be subject to current ARIN policies.
> >> * The minimum IPv4 transfer size is a /24, or the original assignment
> >> size, whichever is smaller.
> >> * The minimum IPv6 transfer size is a /48.
> >> Rationale:
> >> The base intent here is to lower confusion, raise clarity, and level
> >> the bar between 8.2 and 8.3 transfers. M&A transfers are distinct from
> >> specified transfers and not all of the same rules can apply - but many
> >> can and should. Therefor this policy change explicitly adds
> >> requirements which do not exist in 8.2 policy text today: Source must
> >> be the undisputed current registered holder, recipient must sign an
> >> RSA (and is subject to policy), and /24 minimum for IPv4, /48 for
> >> IPv6.
> >> Changes following discussion at the ARIN XXX public policy meeting:
> >> 1) Changed the first bullet. This was an area for objections because
> >> it did not allow chain of custody transfers, so now instead of saying
> >> that the purchased company must be the current registrant holder it
> >> simply says that there can not be any dispute as to who the registered
> >> holder is.
> >> 2) Removed the " such that their continued need is justified" text
> >> from the second bullet, this was another area of debate at the meeting
> >> and justification is already covered in paragraph 2 of 8.2 (which
> >> remains unchanged).
> >> 3) Swapped the first two bullets.
> >> 4) Added "covering all transferred resources" to the RSA bullet, for clarity.
> >> 5) Swapped the third and fourth bullets.
> >> 6) Altered the IPv4 minimum allocation to bring it in line with 4.10
> >> resources and any future exceptions.
> >> Timetable for implementation: immediate
> >> ----8<----8<----8<----
> >> Cheers,
> >> ~Chris
> >> --
> >> @ChrisGrundemann
> >> http://chrisgrundemann.com
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