Wouldn’t “5.7.4.2 The recipient must be an ORG registered with the receiving 
RIR” be simpler and just as effective?

Owen


> On Oct 13, 2020, at 8:29 AM, Anthony Ubah <[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.
> 
> Thanks 
> 
> Kind Regards, 
> 
> Anthony Ubah 
> 
> On Tue, Oct 13, 2020, 3:28 PM John Curran <[email protected] 
> <mailto:[email protected]>> wrote:
> On 13 Oct 2020, at 8:48 AM, John Curran <[email protected] 
> <mailto:[email protected]>> wrote:
>> 
>>> 1. Does the policy impose any conditions on recipient organizations in the 
>>> ARIN region receiving transfers from AFRINIC-served entities?
>>> 
>>> No. The final version of this proposal indicates clearly that no condition 
>>> will be imposed on the recipient’s organization in other regions, which 
>>> obviously also applies to the case of ARIN.
> 
> Anthony - 
> 
> We’re having trouble now reconciling your response above (regarding 
> conditions of recipient organizations in the ARIN region) with the following 
> statement in the provided policy text – 
> 
> "5.7.4.2   The recipient must be an AFRINIC or any RIR member, legacy holders 
> in any region”
> 
> The way the policy text is written makes it very challenging to determine 
> what criteria are to be applied by AFRINIC versus criteria that are to be 
> applied to organizations served by other RIRs, and that was the reason for 
> our two questions about regarding conditions to be imposed on ARIN-region 
> organizations.   Our plain reading of 5.7.4.2 suggests that it would need to 
> be applied by ARIN to ARIN-region recipients.  
> 
> If this is the case, then the proposed policy is not compatible with ARIN’s 
> NRPM 8.4 requirements for compatible transfer policies – as ARIN would need 
> to (despite your earlier response) apply this “member legacy holder” criteria 
> when processing requests by ARIN customers to receive number resources via 
> InterRIR transfer from AFRINIC-served customers.  
> 
> I will observe that there is a real risk of incompatibility when RIRs write 
> specific policy criteria to be applied by other RIRs; in this case, it is 
> worth noting that not all ARIN customers are members or legacy resource 
> holders, and thus the proposed policy as written would not be available to a 
> significant portion of the ARIN community.  (This conflict also points out 
> the value of staff involvement in formal review of proposed InterRIR transfer 
> policies, as there are many details that need to align for smooth transfer 
> processing.)
> 
> Thanks,
> /John
> 
> John Curran
> President and CEO
> American Registry for Internet Numbers
> 
> 
> 
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