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

David Farmer farmer at umn.edu
Mon Sep 30 14:45:39 EDT 2019

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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