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

Owen DeLong owen at delong.com
Fri Oct 11 14:13:22 EDT 2019

> On Oct 10, 2019, at 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.

> 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.

> 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?

> 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.

> 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.

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.

> 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.


> Thanks.
> On Thu, Oct 10, 2019 at 8:51 PM Owen DeLong <owen at delong.com <mailto: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 <mailto: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>
>> 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 <mailto:Email%3Afarmer 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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