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

Fri Oct 11 11:11:43 EDT 2019

Agree with this point od view and I remain opposed to the proposal as
written with any possibility to transfer IPv6 and 32Bit ASN Inter-RIR even
for M&A.

Suggest it to be more clear in the text.

Fernando Frediani

On Thu, 10 Oct 2019, 22:35 David Farmer, <farmer at umn.edu> wrote:

> 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
>> ===============================================
>> _______________________________________________
>> 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
> ===============================================
> _______________________________________________
> ARIN-PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> Unsubscribe or manage your mailing list subscription at:
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