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

Owen DeLong owen at delong.com
Thu Oct 10 21:50:48 EDT 2019

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?


> 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 <mailto:Email%3Afarmer at umn.edu>
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