[arin-ppml] Recommended Draft Policy ARIN-2019-10: Inter-RIR M&A
farmer at umn.edu
Fri Oct 11 01:04:04 EDT 2019
In re-reading the staff comments for ARIN-2019-10, I would support the
staff's recommendations to instead make changes within section 8.4
instead of 8.2, but that is not what the current policy text as written
does. As written I believe the new text is independent of section 8.4 and
would allow IPv6 Inter-RIR transfers and M&A transfers of sections 4.4 and
4.10 resources. Therefore, I can not support this policy as written.
On Thu, Oct 10, 2019 at 10:34 PM 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
> 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
>> 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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