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

[hostmaster at uneedus.com]

I agree.  The only reason for this transfer thing was the shortage of IPv4 
addresses and 16 bit ASN numbers.  There is no shortage of IPv6 addresses 
or 32 bit ASN.

Therefore, I agree that IPv6 transfers and 32 bit ASN transfers should not 
be permitted, even for M&A.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Fri, 11 Oct 2019, Fernando Frediani wrote:

> 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
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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
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