On 13 Oct 2020, at 11:29 AM, Anthony Ubah <[email protected]<mailto:[email protected]>> wrote:
Dear John, Thanks for your prompt reply. I'd like to point out the value for us to communicate directly rather than with intermediaries as it is a more effective process. 5.7.4.2 The recipient must be an AFRINIC or any RIR member, legacy holders in any region This clause is never intended to put a limit on the other RIR’s recipient requirement. It simply puts a requirement for the AFRINIC region. As members are the only RIR customers in our region, it can be interpreted as "the recipient can be customers of other RIR". Will ARIN accept such clarification? Or, would a rewording of “The transfer recipient must be an AFRINIC member or any RIR member or legacy holders in any region, or any kind of entities as other RIRs deem proper” better clarify our intention? We would prefer not to modify policy text at this late stage of policy proposal, but if ARIN insists, we will talk to the chairs in our policy community to see if such editorial change would be acceptable. As policy author, we are not lawyers, nor do we consult with lawyers while we are writing policy proposal. We appreciate if ARIN can tolerate such fine wording in the policy text and accept a more open “intention” oriented interpretaion. Anthony - Your local RIR is your best resource for such engagement, as they can help you with clarity of language and will ultimately need to implement any policy adopted in your region. We will continue to provide formal reviews of InterRIR transfer compatibility as requested by other RIRs – my only advice regarding inter-RIR transfer policy language is a suggestion to be explicit as possible about requirements imposed on those outside your region to the extent feasible. No specific wording is necesary, but as means of an example, you can see how we handle the requirements in the ARIN NRPM 8.4 clauses – • Source entities outside of the ARIN region must ... • Source entities within the ARIN region must …. • The conditions on a recipient outside of the ARIN region will be ... • Recipients within the ARIN region must … Such clarity helps insure that there is complete understanding of the policy intent and any conditions that ARIN might need to consider during its review. ARIN does not ever require any particular language, but clearer policy language makes for faster and more accurate reviews of compatibility with our InterRIR transfer policy requirements. Best wishes, /John John Curran President and CEO American Registry for Internet Numbers
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