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Today's Topics:
1. Re: REVISED: Draft Policy ARIN-2012-8: Aligning 8.2 and 8.3
Transfer Policy (David Farmer)
2. Re: REVISED: Draft Policy ARIN-2012-8: Aligning 8.2 and 8.3
Transfer Policy (John Santos)
3. Re: REVISED: Draft Policy ARIN-2012-8: Aligning 8.2 and 8.3
Transfer Policy (Owen DeLong)
4. Re: REVISED: Draft Policy ARIN-2012-8: Aligning 8.2 and 8.3
Transfer Policy (Owen DeLong)
5. Re: REVISED: Draft Policy ARIN-2012-8: Aligning 8.2 and 8.3
Transfer Policy (Owen DeLong)
----------------------------------------------------------------------
Message: 1
Date: Mon, 19 Nov 2012 14:38:41 -0600
From: David Farmer <[email protected]>
To: Chris Grundemann <[email protected]>
Cc: ARIN PPML <[email protected]>, "[email protected]"
<[email protected]>
Subject: Re: [arin-ppml] REVISED: Draft Policy ARIN-2012-8: Aligning
8.2 and 8.3 Transfer Policy
Message-ID: <[email protected]>
Content-Type: text/plain; charset=ISO-8859-1; format=flowed
On 11/19/12 13:48 , Chris Grundemann wrote:
> On Mon, Nov 19, 2012 at 12:26 PM, Owen DeLong <[email protected]> wrote:
...
>> 3. Suggest updating the minimum transfer size specification to reflect
>> "Current ARIN minimum allocation or assignment policy as defined in section
>> 4 or section 6 or the original assignment size, whichever is smaller." since
>> over time we have seen changes in these minimums and I would prefer that the
>> transfer policy automatically track other policy changes.
>
> I believe that would effectively allow everyone to transfer v4/28s
> today based on 4.10 - is this something the community wants to allow?
> More feedback in this area would also be helpful.
No, I think Owen is mostly right, but I would change the order and
simplify for additional clarity to;
"* The minimum transfer size is, the original allocation size or the
current applicable minimum allocation size in current policy, whichever
is smaller."
I believe that means you can transfer the original allocation size what
ever it is and if you want to transfer something else it must conform to
current policy, that means /28 within the range reserved in 4.10 and /24
for a small multihomed end user, or a /22 for a multihomed ISP, etc...
Put another way, if you are doing only a partial transfer then you can't
break things up smaller than current policy allows, and if the current
block is already smaller, than you can only transfer the whole block.
--
================================================
David Farmer Email: [email protected]
Office of Information Technology
University of Minnesota
2218 University Ave SE Phone: 1-612-626-0815
Minneapolis, MN 55414-3029 Cell: 1-612-812-9952
================================================
------------------------------
Message: 2
Date: Mon, 19 Nov 2012 15:13:33 -0500
From: John Santos <[email protected]>
To: Chris Grundemann <[email protected]>
Cc: ARIN PPML <[email protected]>, "[email protected]"
<[email protected]>
Subject: Re: [arin-ppml] REVISED: Draft Policy ARIN-2012-8: Aligning
8.2 and 8.3 Transfer Policy
Message-ID: <[email protected]>
Content-Type: TEXT/PLAIN; charset=US-ASCII
On Mon, 19 Nov 2012, Chris Grundemann wrote:
> Thanks for the feedback Owen.
>
> On Mon, Nov 19, 2012 at 12:26 PM, Owen DeLong <[email protected]> wrote:
> > 1. first bullet, s/used/use/ in that the acquired assets should still be
> > using the resources in order to justify an M&A transfer.
>
> That would constitute a change from the existing text, which several
> folks spoke against at the PPM. I'd like to get more feedback before
> changing it back again. Comments from others in the community would be
> very much appreciated.
>
Would this effect the case where an organization in financial difficulty
has ceased operations (and so isn't currently using any of the assets),
but the acquiring org is planning to resume operations? Seems to me we
should want to encourage that, rather than encouraging fire sales in
this kind of situation. Maybe adding " and intends to continue or resume
such use" to the first sentence. Or would that constrain the recipient
too much?
> > 2. Third bullet should read "current and future ARIN policies".
>
> Good catch, thanks.
>
> > 3. Suggest updating the minimum transfer size specification to reflect
> > "Current ARIN minimum allocation or assignment policy as defined in section
> > 4 or section 6 or the original assignment size, whichever is smaller."
> > since over time we have seen change
> s in these minimums and I would prefer that the transfer policy automatically
> track other policy changes.
>
> I believe that would effectively allow everyone to transfer v4/28s
> today based on 4.10 - is this something the community wants to allow?
> More feedback in this area would also be helpful.
>
> Cheers,
> ~Chris
>
> >
> > Owen
> >
> >
> > Sent from my iPad
> >
> > On Nov 19, 2012, at 9:55 AM, Chris Grundemann <[email protected]> wrote:
> >
> >> Hail PPML,
> >>
> >> Following discussion at the 30th ARIN PPM, ARIN-2012-8 has been
> >> revised. A change-log has been added to the rationale. Please send
> >> feedback at your earliest convenience.
> >>
> >> ----8<----8<----8<----
> >> Draft Policy ARIN-2012-8 Aligning 8.2 and 8.3 Transfer Policy
> >>
> >> Date: 19 November 2012
> >>
> >> Policy statement:
> >>
> >> Replace the first paragraph of section 8.2 with the following (second
> >> paragraph remains unchanged):
> >>
> >> ARIN will consider requests for the transfer of number resources in
> >> the case of mergers and acquisitions under the following conditions:
> >>
> >> * The new entity must provide evidence that they have acquired assets
> >> that used the resources transferred from the current registrant. ARIN
> >> will maintain an up-to-date list of acceptable types of documentation.
> >> * The current registrant must not be involved in any dispute as to
> >> the status of the transferred resources.
> >> * The new entity must sign an RSA covering all transferred resources.
> >> * The transferred resources will be subject to current ARIN policies.
> >> * The minimum IPv4 transfer size is a /24, or the original assignment
> >> size, whichever is smaller.
> >> * The minimum IPv6 transfer size is a /48.
> >>
> >> Rationale:
> >>
> >> The base intent here is to lower confusion, raise clarity, and level
> >> the bar between 8.2 and 8.3 transfers. M&A transfers are distinct from
> >> specified transfers and not all of the same rules can apply - but many
> >> can and should. Therefor this policy change explicitly adds
> >> requirements which do not exist in 8.2 policy text today: Source must
> >> be the undisputed current registered holder, recipient must sign an
> >> RSA (and is subject to policy), and /24 minimum for IPv4, /48 for
> >> IPv6.
> >>
> >> Changes following discussion at the ARIN XXX public policy meeting:
> >> 1) Changed the first bullet. This was an area for objections because
> >> it did not allow chain of custody transfers, so now instead of saying
> >> that the purchased company must be the current registrant holder it
> >> simply says that there can not be any dispute as to who the registered
> >> holder is.
> >> 2) Removed the " such that their continued need is justified" text
> >> from the second bullet, this was another area of debate at the meeting
> >> and justification is already covered in paragraph 2 of 8.2 (which
> >> remains unchanged).
> >> 3) Swapped the first two bullets.
> >> 4) Added "covering all transferred resources" to the RSA bullet, for
> >> clarity.
> >> 5) Swapped the third and fourth bullets.
> >> 6) Altered the IPv4 minimum allocation to bring it in line with 4.10
> >> resources and any future exceptions.
> >>
> >> Timetable for implementation: immediate
> >> ----8<----8<----8<----
> >>
> >> Cheers,
> >> ~Chris
> >>
> >>
> >> --
> >> @ChrisGrundemann
> >> http://chrisgrundemann.com
> >> _______________________________________________
> >> 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:
> >> http://lists.arin.net/mailman/listinfo/arin-ppml
> >> Please contact [email protected] if you experience any issues.
>
>
>
> --
> @ChrisGrundemann
> http://chrisgrundemann.com
> _______________________________________________
> 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:
> http://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact [email protected] if you experience any issues.
>
>
--
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539
------------------------------
Message: 3
Date: Mon, 19 Nov 2012 17:18:54 -0800
From: Owen DeLong <[email protected]>
To: Chris Grundemann <[email protected]>
Cc: ARIN PPML <[email protected]>, "[email protected]"
<[email protected]>
Subject: Re: [arin-ppml] REVISED: Draft Policy ARIN-2012-8: Aligning
8.2 and 8.3 Transfer Policy
Message-ID: <[email protected]>
Content-Type: text/plain; charset=windows-1252
On Nov 19, 2012, at 11:48 AM, Chris Grundemann <[email protected]> wrote:
> Thanks for the feedback Owen.
>
> On Mon, Nov 19, 2012 at 12:26 PM, Owen DeLong <[email protected]> wrote:
>> 1. first bullet, s/used/use/ in that the acquired assets should still be
>> using the resources in order to justify an M&A transfer.
>
> That would constitute a change from the existing text, which several
> folks spoke against at the PPM. I'd like to get more feedback before
> changing it back again. Comments from others in the community would be
> very much appreciated.
>
>> 2. Third bullet should read "current and future ARIN policies".
>
> Good catch, thanks.
>
>> 3. Suggest updating the minimum transfer size specification to reflect
>> "Current ARIN minimum allocation or assignment policy as defined in section
>> 4 or section 6 or the original assignment size, whichever is smaller." since
>> over time we have seen changes in these minimums and I would prefer that the
>> transfer policy automatically track other policy changes.
>
> I believe that would effectively allow everyone to transfer v4/28s
> today based on 4.10 - is this something the community wants to allow?
> More feedback in this area would also be helpful.
>
It would only allow them to transfer /28s if their target use was a valid
qualified use under 4.10. As such, I think I'm OK with that.
If people object to that, then I would suggest the following:
"Notwithstanding section 4.10, Current ARIN minimum allocation or assignment
policy as defined in section 4 or section 6?"
Owen
------------------------------
Message: 4
Date: Mon, 19 Nov 2012 17:22:39 -0800
From: Owen DeLong <[email protected]>
To: David Farmer <[email protected]>
Cc: ARIN PPML <[email protected]>, "[email protected]"
<[email protected]>
Subject: Re: [arin-ppml] REVISED: Draft Policy ARIN-2012-8: Aligning
8.2 and 8.3 Transfer Policy
Message-ID: <[email protected]>
Content-Type: text/plain; charset=iso-8859-1
+1 -- I support Dave's suggested rewording.
Owen
On Nov 19, 2012, at 12:38 PM, David Farmer <[email protected]> wrote:
> On 11/19/12 13:48 , Chris Grundemann wrote:
>> On Mon, Nov 19, 2012 at 12:26 PM, Owen DeLong <[email protected]> wrote:
> ...
>>> 3. Suggest updating the minimum transfer size specification to reflect
>>> "Current ARIN minimum allocation or assignment policy as defined in section
>>> 4 or section 6 or the original assignment size, whichever is smaller."
>>> since over time we have seen changes in these minimums and I would prefer
>>> that the transfer policy automatically track other policy changes.
>>
>> I believe that would effectively allow everyone to transfer v4/28s
>> today based on 4.10 - is this something the community wants to allow?
>> More feedback in this area would also be helpful.
>
> No, I think Owen is mostly right, but I would change the order and simplify
> for additional clarity to;
>
> "* The minimum transfer size is, the original allocation size or the current
> applicable minimum allocation size in current policy, whichever is smaller."
>
> I believe that means you can transfer the original allocation size what ever
> it is and if you want to transfer something else it must conform to current
> policy, that means /28 within the range reserved in 4.10 and /24 for a small
> multihomed end user, or a /22 for a multihomed ISP, etc...
>
> Put another way, if you are doing only a partial transfer then you can't
> break things up smaller than current policy allows, and if the current block
> is already smaller, than you can only transfer the whole block.
>
> --
> ================================================
> David Farmer Email: [email protected]
> Office of Information Technology
> University of Minnesota
> 2218 University Ave SE Phone: 1-612-626-0815
> Minneapolis, MN 55414-3029 Cell: 1-612-812-9952
> ================================================
------------------------------
Message: 5
Date: Mon, 19 Nov 2012 17:21:34 -0800
From: Owen DeLong <[email protected]>
To: John Santos <[email protected]>
Cc: ARIN PPML <[email protected]>, "[email protected]"
<[email protected]>
Subject: Re: [arin-ppml] REVISED: Draft Policy ARIN-2012-8: Aligning
8.2 and 8.3 Transfer Policy
Message-ID: <[email protected]>
Content-Type: text/plain; charset=us-ascii
My point in proposing this is not to exclude resuming operations (which I would
consider within the spirit of the language I proposed), but to exclude
acquiring assets that used to use resources as an adjunct to acquiring the
resources with no intent of continuing said operations using the resources.
IOW, I want to avoid extending the more lenient 8.2 provisions to a sale where
someone buys $100,000 worth of IP addresses and $20,000 worth of hardware and
then sells the hardware to $SCRAP_DEALER just to keep the addresses.
Those kinds of purchases belong under the scrutiny of 8.3.
Owen
On Nov 19, 2012, at 12:13 PM, John Santos <[email protected]> wrote:
> On Mon, 19 Nov 2012, Chris Grundemann wrote:
>
>> Thanks for the feedback Owen.
>>
>> On Mon, Nov 19, 2012 at 12:26 PM, Owen DeLong <[email protected]> wrote:
>>> 1. first bullet, s/used/use/ in that the acquired assets should still be
>>> using the resources in order to justify an M&A transfer.
>>
>> That would constitute a change from the existing text, which several
>> folks spoke against at the PPM. I'd like to get more feedback before
>> changing it back again. Comments from others in the community would be
>> very much appreciated.
>>
>
> Would this effect the case where an organization in financial difficulty
> has ceased operations (and so isn't currently using any of the assets),
> but the acquiring org is planning to resume operations? Seems to me we
> should want to encourage that, rather than encouraging fire sales in
> this kind of situation. Maybe adding " and intends to continue or resume
> such use" to the first sentence. Or would that constrain the recipient
> too much?
>
>
>>> 2. Third bullet should read "current and future ARIN policies".
>>
>> Good catch, thanks.
>>
>>> 3. Suggest updating the minimum transfer size specification to reflect
>>> "Current ARIN minimum allocation or assignment policy as defined in section
>>> 4 or section 6 or the original assignment size, whichever is smaller."
>>> since over time we have seen change
>> s in these minimums and I would prefer that the transfer policy
>> automatically track other policy changes.
>>
>> I believe that would effectively allow everyone to transfer v4/28s
>> today based on 4.10 - is this something the community wants to allow?
>> More feedback in this area would also be helpful.
>>
>> Cheers,
>> ~Chris
>>
>>>
>>> Owen
>>>
>>>
>>> Sent from my iPad
>>>
>>> On Nov 19, 2012, at 9:55 AM, Chris Grundemann <[email protected]> wrote:
>>>
>>>> Hail PPML,
>>>>
>>>> Following discussion at the 30th ARIN PPM, ARIN-2012-8 has been
>>>> revised. A change-log has been added to the rationale. Please send
>>>> feedback at your earliest convenience.
>>>>
>>>> ----8<----8<----8<----
>>>> Draft Policy ARIN-2012-8 Aligning 8.2 and 8.3 Transfer Policy
>>>>
>>>> Date: 19 November 2012
>>>>
>>>> Policy statement:
>>>>
>>>> Replace the first paragraph of section 8.2 with the following (second
>>>> paragraph remains unchanged):
>>>>
>>>> ARIN will consider requests for the transfer of number resources in
>>>> the case of mergers and acquisitions under the following conditions:
>>>>
>>>> * The new entity must provide evidence that they have acquired assets
>>>> that used the resources transferred from the current registrant. ARIN
>>>> will maintain an up-to-date list of acceptable types of documentation.
>>>> * The current registrant must not be involved in any dispute as to
>>>> the status of the transferred resources.
>>>> * The new entity must sign an RSA covering all transferred resources.
>>>> * The transferred resources will be subject to current ARIN policies.
>>>> * The minimum IPv4 transfer size is a /24, or the original assignment
>>>> size, whichever is smaller.
>>>> * The minimum IPv6 transfer size is a /48.
>>>>
>>>> Rationale:
>>>>
>>>> The base intent here is to lower confusion, raise clarity, and level
>>>> the bar between 8.2 and 8.3 transfers. M&A transfers are distinct from
>>>> specified transfers and not all of the same rules can apply - but many
>>>> can and should. Therefor this policy change explicitly adds
>>>> requirements which do not exist in 8.2 policy text today: Source must
>>>> be the undisputed current registered holder, recipient must sign an
>>>> RSA (and is subject to policy), and /24 minimum for IPv4, /48 for
>>>> IPv6.
>>>>
>>>> Changes following discussion at the ARIN XXX public policy meeting:
>>>> 1) Changed the first bullet. This was an area for objections because
>>>> it did not allow chain of custody transfers, so now instead of saying
>>>> that the purchased company must be the current registrant holder it
>>>> simply says that there can not be any dispute as to who the registered
>>>> holder is.
>>>> 2) Removed the " such that their continued need is justified" text
>>>> from the second bullet, this was another area of debate at the meeting
>>>> and justification is already covered in paragraph 2 of 8.2 (which
>>>> remains unchanged).
>>>> 3) Swapped the first two bullets.
>>>> 4) Added "covering all transferred resources" to the RSA bullet, for
>>>> clarity.
>>>> 5) Swapped the third and fourth bullets.
>>>> 6) Altered the IPv4 minimum allocation to bring it in line with 4.10
>>>> resources and any future exceptions.
>>>>
>>>> Timetable for implementation: immediate
>>>> ----8<----8<----8<----
>>>>
>>>> Cheers,
>>>> ~Chris
>>>>
>>>>
>>>> --
>>>> @ChrisGrundemann
>>>> http://chrisgrundemann.com
>>>> _______________________________________________
>>>> 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:
>>>> http://lists.arin.net/mailman/listinfo/arin-ppml
>>>> Please contact [email protected] if you experience any issues.
>>
>>
>>
>> --
>> @ChrisGrundemann
>> http://chrisgrundemann.com
>> _______________________________________________
>> 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:
>> http://lists.arin.net/mailman/listinfo/arin-ppml
>> Please contact [email protected] if you experience any issues.
>>
>>
>
> --
> John Santos
> Evans Griffiths & Hart, Inc.
> 781-861-0670 ext 539
------------------------------
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