Re: [sig-policy] prop-130-v002: Secretariat impact assessment

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…."

On 16 Feb 2020, at 11:55 am, JORDI PALET MARTINEZ <jordi.palet@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-bounces@lists.apnic.net en nombre de sunny@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.palet@theipv6company.com <mailto:jordi.palet@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)

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