Hi Adam,

 

I’m not native english speaker either, and probably, because I learnt it by 
myself, have a lot of deficiences.

 

All the policies may have implementation issues. I don’t think this is a 
problem at all, just increase the implementation time, that’s just fine, and 
this was my response to that.

 

The policy doesn’t pretend to be an Inter-RIR IPv6 transfer. The policy 
recognize that if there is an M&A (which are happening every other day),  where 
several type of resources are involved, it should be possible to get a solution 
for all them. It will not make sense to do an M&A for IPv4 only, when we try to 
move to IPv6. It is an incredible innecesary ban to ask a corporation that 
acquired another (or part of it) “renumber”, if for example, they are just 
moving the VMs from one datacenter in Amsterdam to a data center in Brisbane 
(or the other way around). Because with VMs you just need to resync them, and 
once done, get activated in the new location and deactivated in the old one.

 

I can’t believe that anyone suggest that we can tell this organization: we 
allow you to do that for IPv4 but for IPv6, you need to renumber.

 

When I said full implementation I mean that the implementation involving 
several RIRs can be finished, let’s say in 6 months for APNIC, RIPE may take 
just 4, and maybe LACNIC needs 8. It is just an example. Consequently, after 
APNIC finish the implementation, if there in an M&A case APNIC-RIPE, it will be 
possible, but may be a case APNIC-LACNIC needs to wait for 2 additional months 
to be completed (at least using “automation” between the systems of both RIRs).

 

Regards,

Jordi

@jordipalet

 

 

 

El 17/2/20 11:54, "Adam Gosling" <[email protected]> escribió:

 

Hi Jordi

Please stop saying you are “clarifying” policy text when you are actually 
changing policy. People with English as a second language may misunderstand 
what is happening.

I’m supportive of more specific language in the M&A policy, but this is 
basically an inter-RIR IPv6 transfer policy.

I do not support this policy proposal because I doubt there are sufficient 
legitimate use cases to justify the significant implementation burden, 
technical issues, and legal work this would create for the Secretariat(s). 

Your response to the assessment provided by Sunny doesn’t address the technical 
implementation issues. When the Secretariat tells you that it is a 6-month 
timeframe it is because it is complex and expensive to do. Simply saying you 
understand the implementation issues for APNIC and other RIRs doesn’t change 
this. It should mean that you have to work hard to demonstrate there is a 
community need for the change. Also, I’m not sure what you mean by “full” 
implementation. You can’t have a half implemented Policy.

In my opinion, you haven’t provided sufficient justification for this change in 
policy and I think it’s a bad idea for a host of reasons.

My recommendation is that the Secretariat editorially “clarify” Sections 8.4, 
11.0, and 13.3 to explicitly say "APNIC will only recognize the intra-RIR 
transfer of…."

Regards,

Adam

 



On 16 Feb 2020, at 11:55 am, JORDI PALET MARTINEZ <[email protected]> 
wrote:

 

Hi Sunny, all,

I understand that your assesment for this proposal is only informational inputs 
and not suggesting any text changes, in the sense that:

1) The M&A from/to other regions will need to be verified by the counter-party 
RIR. I expect that this is part of the operational procedure, and I suggest to 
use the same as you actually have for Inter-RIR transfers, may be requiring 
slight modifications. However, I don't think it is relevant to include that in 
the policy text, and instead should be fully managed by the staff.

2) I fully understand that there are implementation implications, not only in 
APNIC systems, but also in couter-party RIRs, and the "full" implementation 
will depend on all that.

Let me know if otherwise you think "anything" should be added/clarified in the 
policy proposal.

Regards,
Jordi
@jordipalet



El 14/2/20 14:49, "Srinivas Chendi" <[email protected] en 
nombre de [email protected]> escribió:

   Dear SIG members,

   Here is the Secretariat impact assessment for proposal “prop-130-v002: 
   Modification of transfer policies” and the same is also published at:

        https://www.apnic.net/community/policy/proposals/prop-130/

   Staff comments
   --------------

   Possible difficulties in verifying mergers, acquisition, reorganization, 
   or relocation from out of APNIC region due to unfamiliarity of languages 
   and legal systems.

   The NRO comparative policy matrix indicates APNIC Members outside of the 
   region must have network presence in the Asia Pacific. Additionally, 
   some RIRs have an ‘out of region’ policy which restricts where they can 
   use their resources.

   Members may face difficulties updating their domain objects if there has 
   been a partial IPv6 transfer where a larger block has been de-aggregated.


   Technical comments
   ------------------

   APNIC’s current systems are not configured to handle inter-RIR IPv6 
   reverse DNS. This will need to be developed.

   APNIC cannot predict when other RIRs will support IPv6 reverse DNS 
   fragments incoming to their systems.


   Legal comments
   --------------

   This will affect how APNIC verifies M&A documents. May require cross RIR 
   coordination.


   Implementation
   --------------

   6 months


   Regards
   Sunny


   On 20/01/2020 10:16 am, Bertrand Cherrier wrote:


Dear SIG members,

A new version of the proposal "prop-130: Modification of transfer policies"
has been sent to the Policy SIG for review.

It will be presented during the Open Policy Meeting at APNIC 49 in
Melbourne,
Australia on Thursday, 20 February 2020.

We invite you to review and comment on the proposal on the mailing list
before the meeting.

The comment period on the mailing list before an APNIC meeting is an
important part of the policy development process. We encourage you to
express your views on the proposal:

 * Do you support or oppose this proposal?
 * Does this proposal solve a problem you are experiencing? If so, tell
   the community about your situation.
 * Do you see any disadvantages in this proposal?
 * Is there anything in the proposal that is not clear?
 * What changes could be made to this proposal to make it more effective?

Information about this proposal is available at:
http://www.apnic.net/policy/proposals/prop-130

Regards

Sumon, Bertrand, Ching-Heng
APNIC Policy SIG Chairs

------------------------------------------------------------------------

prop-130-v002: Modification of transfer policies

------------------------------------------------------------------------

Proposer: Jordi Palet Martinez
[email protected] <mailto:[email protected]>


   1. Problem statement

Existing transfer policies for IPv4, IPv6 and ASN resources have some
differences
among what is allowed and what not, if in the case of intra-RIR and
inter-RIR, and
it is not clear if in case of merger and acquisitions it is referring to
a complete
company, part of it, or even if in case of a company reorganization or
relocation,
the policy is supportive to that case.

In the case of inter-RIR, the counterpart RIR need to have a reciprocal
policy or
procedure that allows it.


   2. Objective of policy change

To ensure that the policy text is clarified, if those cases are
supported by the
community. It will also facilitate companies or business units, moving
or being established
in other regions.


   3. Situation in other regions

There is a variety of support of all those cases in different regions.
The one more open is
RIPE, followed by ARIN. Similar policy proposals are being submitted in
LACNIC and AFRINIC.


   4. Proposed policy solution

Actual Text
8.4. Mergers & acquisitions

APNIC will process and record the transfer of IPv4 resources as the
result of merger or acquisition.

11.0. Transfer of IPv6 resources

APNIC will only recognize the transfer or IPv6 addresses as the result
of Merger & Acquisition activity.
The following conditions and consequences apply.

13.3. Mergers & acquisitions

APNIC will recognize the transfer of ASNs as the result of merger or
acquisition.

Proposed Text
8.4. Mergers, acquisitions and relocations

APNIC will process and record the transfer of IPv4 resources as the
result of a partial or complete merger,
acquisition, reorganization or relocation, in both cases, intra-RIR and
inter-RIR.

In the case of inter-RIR, the counterpart RIR need to have a reciprocal
policy/procedure that allows it.

11.0. Transfer of IPv6 resources

APNIC will only recognize the transfer or IPv6 addresses as the result
of a partial or complete merger,
acquisition, reorganization or relocation activity, in both cases,
intra-RIR and inter-RIR. The following
conditions and consequences apply.

In the case of inter-RIR, the counterpart RIR need to have a reciprocal
policy/procedure that allows it.

13.3. Mergers, acquisitions and relocations

APNIC will recognize the transfer of ASNs as the result of a partial or
complete merger, acquisition,
reorganization or relocation activity, in both cases, intra-RIR and
inter-RIR.

In the case of inter-RIR, the counterpart RIR need to have a reciprocal
policy/procedure that allows it.


   5. Advantages / Disadvantages

Advantages:
Fulfilling the objectives above indicated.

Disadvantages:
It could be considered that it can create further dis-aggregation,
especially in IPv6, however, those cases
are rare and only happening from time to time, so the impact is
negligible, and justified by the documentation
provided to the secretariat.


   6. Impact on resource holders

None.


   7. References

https://www.ripe.net/publications/docs/ripe-682
https://www.arin.net/policy/nrpm.html#eight2

Cordialement,

------------------------------------------------------------------------

Bertrand Cherrier
Micro Logic Systems
https://www.mls.nc
Tél : +687 24 99 24
VoIP : 65 24 99 24
SAV : +687 36 67 76 (58F/min)


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partially, including attached files, is strictly prohibited and will be 
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that any disclosure, copying, distribution or use of the contents of this 
information, even if partially, including attached files, is strictly 
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