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.
Thank you. On Thu, Oct 10, 2019 at 10:34 PM David Farmer <[email protected]> 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 <[email protected]> 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 <[email protected]> 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:[email protected] >> 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 >> the ARIN Public Policy Mailing List ([email protected]). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. >> >> >> > > -- > =============================================== > David Farmer Email:[email protected] > 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:[email protected] 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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