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

  • To: JORDI PALET MARTINEZ <jordi.palet@consulintel.es>
  • Subject: Re: [sig-policy] prop-130-v002: Secretariat impact assessment
  • From: Adam Gosling <email@adamgosling.com>
  • Date: Mon, 17 Feb 2020 10:52:38 +1000
  • Cc: mailman_SIG-policy <sig-policy@apnic.net>
  • Delivered-to: sig-policy@clove.apnic.net
  • In-reply-to: <572DE9D4-EAC8-4FDA-A10E-293E865804EC@consulintel.es>
  • List-archive: <http://mailman.apnic.net/mailing-lists/sig-policy/>
  • List-help: <mailto:sig-policy-request@lists.apnic.net?subject=help>
  • List-id: APNIC SIG on resource management policy <sig-policy.lists.apnic.net>
  • List-post: <mailto:sig-policy@lists.apnic.net>
  • List-subscribe: <https://mailman.apnic.net/mailman/listinfo/sig-policy>, <mailto:sig-policy-request@lists.apnic.net?subject=subscribe>
  • List-unsubscribe: <https://mailman.apnic.net/mailman/options/sig-policy>, <mailto:sig-policy-request@lists.apnic.net?subject=unsubscribe>
  • References: <572DE9D4-EAC8-4FDA-A10E-293E865804EC@consulintel.es>

    • 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.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)


      *              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. The information is intended to be for the exclusive use of the individual(s) named above and further non-explicilty authorized disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited and will be considered a criminal offense. If you are not the intended recipient be aware that any disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited, will be considered a criminal offense, so you must reply to the original sender to inform about this communication and delete it.



      *              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