[arin-ppml] Recommended Draft Policy ARIN-2019-10: Inter-RIR M&A

[David Farmer]

I'm fine with what Staff has been doing, the current inter-RIR policy in
section 8.4 clearly doesn't allow IPv6 transfers.

However, the new text added to section 8.2 seems to clearly allow inter-RIR
M&A transfers independent of what section 8.4 has to say and its exclusion
of IPv6.
Current M&A transfers include all resource types, IPv4, IPv6, and ASN.  By
adding this new text without any reference to section 8.4 or a clear
exclusion of IPv6 in the text added, I have to conclude the text intends to
allow inter-RIR M&A transfers of IPv6 and section 4.4 and 4.10 resources,
which the current section 8.2 allows.

If that is not the community's intent then the text added should refer to
section 8.4 or include an explicit exclusion of IPv6 for inter-RIR M&A
transfers, and 4.4 and 4.10 resources as well, if they are not to be
transferred by inter-RIR M&As.

Furthermore, if you intend an inter-RIR M&A transfer to use section 8.4 to
execute the inter-RIR transfer, you will need to consider the meaning the
hold time in the third bullet point of section 8.4, and the effect you
intend it to have.

I cannot support the text as written, the staff interpretation doesn't jive
with my interpretation of the text, and I don't think the current text
jives with the intent of a large portion of the community either.

Section 4.1 of the PDP says, "Internet number resource policy must provide
for fair and impartial management of resources according to unambiguous
guidelines and criteria."

In my opinion, as written this text is not unambiguous. If the community
expects 8.4 to be followed to execution an inter-RIR M&A transfer the text
should say that, better yet the text should clearly exclude IPv6 and maybe
section 4.4 and 4.10 resources, on its own, if that is the intent of the
community.

Thanks.

On Thu, Oct 10, 2019 at 8:51 PM Owen DeLong <owen at delong.com> wrote:

> Are you asking why the proposed policy doesn’t effect this change to
> current staff action, or are you asking why staff action didn’t change when
> they started accepting 8.2-based inter-RIR transfers without a policy
> change?
>
> Owen
>
>
> On Sep 30, 2019, at 11:45 , David Farmer <farmer at umn.edu> wrote:
>
> I have a question regarding the Staff Understating of the policy from the
> Staff and Legal Assessment of the policy, which says the following;
>
> Staff understands the intent of the draft policy is to clarify handling of
> mergers and acquisition transfer processing between RIRs who have
> compatible transfer policies. The proposed change would not be a change
> from present practice but the policy change would make our implementation
> of the current policy clearer. It is understood that IPv6 would be excluded
> since this refers to Inter-RIR transfers in which IPv6 is not permitted to
> be part of the transfer.
>
> Where the new policy text says;
>
> When merger, acquisition, or reorganization activity results in surviving
> legal entity that is incorporated outside the ARIN service region, or
> focused outside the ARIN service region, or is merging with an organization
> that already has a relationship with another RIR, then resources may be
> moved to another RIR in accordance with the receiving RIR’s policies.
>
> So my question is;
>
> What in the new policy text justifies the exclusion of transfers of IPv6
> resources for Inter-RiR M&A transfers? The new policy text doesn't directly
> reference section 8.4 which clearly doesn't include IPv6. However, nothing
> explicitly includes IPv6 in section 8.2 for the current Intra-region M&A
> transfers, so what excludes them for Inter-RIR M&A transfers?
>
> While I agree a segment of the community doesn't want there to be
> inter-RIR M&A transfers of IPv6, I don't believe that is what this policy
> text says. If the community's intent is to clarify the status quo then and
> not allow inter-RIR M&A transfers of IPV6, then I believe there needs to be
> an explicit exclusion for IPv6 in Internet-RIR M&A transfers. Otherwise, I
> believe the text as written includes IPv6 inter-RIR M&A transfers.
>
> I cannot support this policy as written, either the policy statement needs
> to be updated to explicitly exclude IPv6 from inter-RIR M&A or the staff
> understating needs to updated to include IPv6 for inter-RIR M&A, because as
> it stands, I believe the staff undressing and the policy text are
> inconsistent with each other.
>
> Thank you.
>
> --
> ===============================================
> 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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-- 
===============================================
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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