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

David Farmer farmer at umn.edu
Fri Oct 11 16:34:40 EDT 2019 

On Fri, Oct 11, 2019 at 1:13 PM Owen DeLong <owen at delong.com> wrote:

> On Oct 10, 2019, a 20:34 , 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.
>
> Staff has been currently allowing M&A inter-RIR transfers of IPv4 and ASNs
> even though there’s no policy permitting or prohibiting it.
>

I have to disagree, the current 8.4 text clearly allows transfers our of
our region and justification happens at the receiving end, so at least
outbound M&A transfers seem to in complete compliance with section 8.4 in
my opinion.  I'll grant you inbound M&A transfers, without justification
for the resource received might be stretching things a little. But,
inter-RIR transfers, in general, are outbound from ARIN, and I don't see an
obvious reason that wouldn't be the case for inter-RIR M&A transfers as
well.


> 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.
>
> As I understand it, the intent of the new text in 8.2 is to document that
> what staff has been doing is allowed. There is no intent to expand the
> scope of what is permitted in inter-RIR transfers.
>

We can agree to disagree, that's not how I read the problem statement.

> 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.
>
>
> I’m all for clarification of the policy text. Can that be achieved without
> sending the policy back to draft status?
>

I see no reason to be in a hurry, the staff is doing what I think the
community wants, let's get the text right.

> 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 don’t intend anything, per se. I didn’t propose it, nor do I have any
> particularly strong stake in the outcome. However, it was presented to the
> community as a clarification of existing process, not an expansion of that
> process. As such, I sought (and received) clarification from staff that
> their interpretation of the policy would not, in fact, expand their
> treatment of inter-RIR M&A transfers.
>

Again that's not how I read the problem statement.

> 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.
>
>
> As I interpret it, the current text provides slightly more clarity than
> the existing text while leaving the possibility of M&A transfers of IPv6 as
> an open question in the written words. Staff has stated that they will
> continue to interpret IPv6 transfers as not being permitted, so I have no
> objection to the policy as written since it does provide some clarity that
> is currently lacking without actually affecting staff action.
>

Again I dispute the staff interruption of the currently proposed text.
Also, the staff recommended a completely different way to accomplish what
you and most of the community seems to want. I support the staff's
recommendation for modifying 8.4 instead of 8.2, I think it will result in
much less ambiguity.


> I agree that greater clarity that IPv6 M&A transfers are not allowed would
> be preferable. I would support amending this proposal to achieve that,
> especially if it can be accomplished without reverting to draft policy.
>

Again what's the hurry here?

> 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.
>
>
> In my opinion, this text is not the issue. The existing text is even more
> ambiguous, so I see this as a step in the correct direction.
>
> Owen
>
>
> 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
> ===============================================
>
>
>

-- 
===============================================
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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