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 > <jordi.pa...@consulintel.es> 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" <sig-policy-boun...@lists.apnic.net en > nombre de su...@apnic.net> 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 >> jordi.pa...@theipv6company.com <mailto:jordi.pa...@theipv6company.com> >> >> >> 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) >> >> >> * sig-policy: APNIC SIG on resource management policy >> * >> _______________________________________________ >> sig-policy mailing list >> sig-policy@lists.apnic.net >> https://mailman.apnic.net/mailman/listinfo/sig-policy >> > * sig-policy: APNIC SIG on resource management policy > * > _______________________________________________ > sig-policy mailing list > sig-policy@lists.apnic.net > https://mailman.apnic.net/mailman/listinfo/sig-policy > > > > ********************************************** > IPv4 is over > Are you ready for the new Internet ? > http://www.theipv6company.com > The IPv6 Company > > This electronic message contains information which may be privileged or > confidential. 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