I agree. The only reason for this transfer thing was the shortage of IPv4 addresses and 16 bit ASN numbers. There is no shortage of IPv6 addresses or 32 bit ASN.

Therefore, I agree that IPv6 transfers and 32 bit ASN transfers should not be permitted, even for M&A.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Fri, 11 Oct 2019, Fernando Frediani wrote:

Agree with this point od view and I remain opposed to the proposal as written with 
any possibility to transfer IPv6 and 32Bit ASN Inter-RIR even for M&A.
Suggest it to be more clear in the text.

Fernando Frediani

On Thu, 10 Oct 2019, 22:35 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
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--
===============================================
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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