[arin-ppml] Draft Policy ARIN-2019-4: Allow Inter-regional IPv6 Resource Transfers

David Farmer farmer at umn.edu
Fri Apr 5 12:41:14 EDT 2019


I'll agree, what we are talking about is not strictly speaking an M&A in
some cases, but in other cases, M&A activity could be the trigger.
However, at a high level, I think we are talking about transfers to or from
the same entity or closely associated entities, but between the RIRs. To
me, this seems more related to the intent of section 8.2 and things like
M&As and reorganization, etc...

We probably need to add an additional word to the title of section 8.2,
maybe "Relocations", for "Mergers, Acquisitions, Reorganizations, and
Relocations"

In any case, I have not heard people advocating for IPv6 transfers to a
completely unrelated (designated) organization which is the primary intent
of sections 8.3, 8.4 and 8.5. Yes, you can designate your organization in
the other RIR, but that was more of a side effect than the primary intent
of these policies. Furthermore, there seems to be some strong opposition to
IPv6 transfers to an unrelated organization, in the ARIN region or a
different region, and since no one seems to be advocating for that, I'm
trying to explore what could possibly work.

What I'm suggesting is modifying 8.2 to account for these transfers
effectively to the same or associated organization but under the control of
another RIR

Maybe a policy statement something like the following;

Add "Relocations" to the title of section 8.2;

8.2 Mergers, Acquisitions, Reorganizations, and Relocations

Add the following to the end of the text for section 8.2;

OR

The resources are being transferred to the administration of another RIR in
the name of the current registrant or an organization under common control
with the current registrant.


Comments or suggestions, please.

Thanks.

On Thu, Apr 4, 2019 at 3:29 PM Jay Borkenhagen <jayb at braeburn.org> wrote:

> David,
>
> The thing this policy proposal seeks to permit is a different kind of
> transfer than what you cite.
>
> It has nothing to do with transfers related to M&A activity involving
> the resource holder.
>
> What's under discussion is the case where someone holds a resource
> that is currently administered by one RIR, and they would like another
> RIR to administer it in the future.  Perhaps the resource is now with
> APNIC, and the resource holder would prefer the entire resource to be
> administered by ARIN instead.  Or perhaps it's now with ARIN, and the
> resource holder would prefer the whole thing to be moved to LACNIC.
>
> Thanks.
>
>                                                 Jay B.
>
>
> David Farmer writes:
>  > Thanks for clarifying the policy you were referring to.
>  >
>  > In ARIN Transfer Policy there are significant differences between IPv4,
>  > ASNs, and IPv6, are you suggesting all these differences should be
>  > eliminated? Or are you suggesting an equivalent mechanism to transfer
> IPv6
>  > resources inter-regionally is needed to the one that exists for
>  > transferring IPv6 within the ARIN region?
>  >
>  > Currently, ARIN Transfer Policy allows;
>  >
>  > A. All resource types to be transferred within the ARIN region as part
> of a
>  > Merger, Acquisition, or Reorganization (Section 8.2).
>  >
>  > B. Only IPv4 and ASNs to be transferred to unrelated organizations (a
>  > designated organization) within the region or to another region
> (Sections
>  > 8.3, 8.4, and 8.5).
>  >
>  > Option A has been the case for a long time, whereas option B is more
> recent
>  > and mostly a result of IPv4 runout and the approaching runout of 16-bit
>  > ASNs. Further, there are differences in how a transfer is
>  > justified between the two options; in option A, legal documentation
>  > justifies the transfer, whereas in option B the need of the recipient
>  > organization justifies the transfer.
>  >
>  > There are two different ways to modify the current policy to accomplish
>  > inter-regional transfers of IPv6 resource;
>  >
>  > 1. Modify option A above to include inter-regional transfers.
>  > 2. Modify option B above to include IPv6.
>  >
>  > By my read of the community, there are strong objections to option #2,
>  > expanding option B to include IPv6. Whereas there seems to be some
>  > acknowledgment that option #1, expanding Option A to include transfers
> to
>  > other regions, could be reasonable.
>  >
>  > Put another way, the greatest objections seems to be allowing IPv6
>  > transfers to unrelated organizations either within the region or to
> other
>  > regions, and far fewer objections to allowing IPv6 transfers to related
>  > organizations in another region.
>  >
>  > I think for the community to evaluate these two options it needs to
>  > understand the use-cases people have for inter-region IPv6 transfers.
> The
>  > use-cases brought up by Jordi and the problem statement seems to fall
>  > within expanding option A to include inter-region transfers.  So unless
>  > someone else has use-cases that need option B to be expanded to include
>  > IPv6, then expanding option A to include inter-region transfers seems
> less
>  > controversial and more likely to gain consensus.
>  >
>  > So looking for what seems possible; I suggest we focus on option #1,
>  > expanding option A to include inter-region transfers, rather than option
>  > #2, expanding option B to include IPv6.
>  >
>  > Comments and suggestions, please.
>  >
>  >
>  > On Wed, Apr 3, 2019 at 3:33 PM Tal, Guy <guy.tal at centurylink.com>
> wrote:
>  >
>  > > What's the difference between an ipv4 address and an ipv6 address
> (other
>  > > than a couple of bits)?
>  > >
>  > > Guy
>  > >
>  > > -----Original Message-----
>  > > From: Steven Ryerse <SRyerse at eclipse-networks.com>
>  > > Sent: Wednesday, April 3, 2019 1:15 PM
>  > > To: Tal, Guy <guy.tal at level3.com>; ARIN <info at arin.net>;
>  > > arin-ppml at arin.net
>  > > Subject: RE: [arin-ppml] Draft Policy ARIN-2019-4: Allow
> Inter-regional
>  > > IPv6 Resource Transfers
>  > >
>  > > Although I agree conceptually, I'm not sure its practical to have all
>  > > policies apply to both IP4 & IP6.  They are different and the
> differences
>  > > require polices that cover the differences.
>  > >
>  > >
>  > > Steven Ryerse
>  > > President
>  > > 100 Ashford Center North, Suite 110, Atlanta, GA  30338
>  > > 770.656.1460 - Cell
>  > > 770.399.9099 - Office
>  > > 770.392.0076 - Fax
>  > >
>  > > ℠ Eclipse Networks, Inc.
>  > >                      Conquering Complex Networks℠
>  > >
>  > > -----Original Message-----
>  > > From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Tal, Guy
>  > > Sent: Wednesday, April 3, 2019 3:47 PM
>  > > To: ARIN <info at arin.net>; arin-ppml at arin.net
>  > > Subject: Re: [arin-ppml] Draft Policy ARIN-2019-4: Allow
> Inter-regional
>  > > IPv6 Resource Transfers
>  > >
>  > > Sorry all, this is the thread I meant to throw my support behind, not
>  > > ARIN-2018-5. I think we should treat v6 the same as v4, resource is
>  > > resource.
>  > >
>  > > Thanks,
>  > > Guy
>  > >
>  > > -----Original Message-----
>  > > From: ARIN <info at arin.net>
>  > > Sent: Tuesday, March 26, 2019 12:52 PM
>  > > To: arin-ppml at arin.net
>  > > Subject: [arin-ppml] Draft Policy ARIN-2019-4: Allow Inter-regional
> IPv6
>  > > Resource Transfers
>  > >
>  > > On 21 March 2019, the ARIN Advisory Council (AC) accepted
>  > > "ARIN-prop-263: Allow Inter-regional IPv6 Resource Transfers" as a
> Draft
>  > > Policy.
>  > >
>  > > The Draft Policy text is below and can be found at:
>  > > https://www.arin.net/participate/policy/drafts/2019_4/
>  > >
>  > > You are encouraged to discuss all Draft Policies on PPML. The AC will
>  > > evaluate the discussion in order to assess the conformance of this
> draft
>  > > policy with ARIN's Principles of Internet number resource policy as
> stated
>  > > in the Policy Development Process (PDP). Specifically, these
> principles are:
>  > >
>  > > * Enabling Fair and Impartial Number Resource Administration
>  > > * Technically Sound
>  > > * Supported by the Community
>  > >
>  > > The PDP can be found at:
>  > > https://www.arin.net/participate/policy/pdp/
>  > >
>  > > Draft Policies and Proposals under discussion can be found at:
>  > > https://www.arin.net/participate/policy/drafts/
>  > >
>  > > Regards,
>  > >
>  > > Sean Hopkins
>  > > Policy Analyst
>  > > American Registry for Internet Numbers (ARIN)
>  > >
>  > >
>  > >
>  > > Draft Policy ARIN-2019-4: Allow Inter-regional IPv6 Resource Transfers
>  > >
>  > > Problem Statement:
>  > >
>  > > There is an operational need to allow RIR transfers of IPv6 resources
>  > > between RIRs with an equivalent transfer policy. ARIN’s RPKI Trust
> Anchor
>  > > (TA) is measurably less widely deployed than TAs from other RIRs.
>  > > As a consequence, RPKI ROAs published through ARIN offer less value.
>  > > Operators seeking to extract the most value from their investment in
>  > > IPv6 would benefit from the ability to transfer IPv6 resources to RIRs
>  > > with more widely deployed RPKI Trust Anchors.
>  > >
>  > > Policy Statement:
>  > >
>  > > Change the first sentence in section 8.4 from:
>  > >
>  > > “Inter-regional transfers of IPv4 number resources and ASNs may take
> place
>  > > only via RIRs who agree to the transfer and share reciprocal,
> compatible
>  > > needs-based policies.”
>  > >
>  > > To:
>  > >
>  > > “Inter-regional transfers of Internet number resources may take place
> only
>  > > via RIRs who agree to the transfer and share reciprocal, compatible
>  > > needs-based policies.”
>  > >
>  > > Comments:
>  > >
>  > > Timetable for implementation: Immediate
>  > > _______________________________________________
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>  >
>  > --
>  > ===============================================
>  > David Farmer               Email:farmer at umn.edu
>  > Networking & Telecommunication Services
>  > Office of Information Technology
>  > University of Minnesota
>  > 2218 University Ave SE        Phone: 612-626-0815
>  > Minneapolis, MN 55414-3029   Cell: 612-812-9952
>  > ===============================================
>  > _______________________________________________
>  > ARIN-PPML
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-- 
===============================================
David Farmer               Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE        Phone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
===============================================
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