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 APRICOT2021/APNIC 51
online-only conference on Wednesday, 03 February 2021.
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 conference 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,
Bertrand and Ching-Heng
APNIC Policy SIG Chairs
-------------------------------------------------------
prop-130-v003: Modification of transfer policies
-------------------------------------------------------
Proposer: Jordi Palet Martnez
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 some regions, this may not be a policy, but an administrative
procedure, but this may change in the future by means of a policy proposal.
In the caser of inter-RIR, the counterpart RIR need to have a reciprocal
policy or procedure that allows it.
Finally, there should not be differences from the APNIC perspective, on
the considerations of an M&A for different type of resources, because
there is no reason for allowing, for example, IPv4 resources to be
transferred, and instead IPv6 ones not. For example, an organization may
be hosting services in a Data Center, by means of Virtual Machines and
moving to a different DC in another region. It is ridiculous to allow to
keep the IPv4 addresses (so not renumber the VMs) and instead ask to
renumber IPv6. It is a big and unnecessary disruptive complexity.
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.
It will minimize legal issues in case an acquisition claiming their
rights over the acquired company and their existing assets (resources).
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 and LACNIC. A similar policy
proposal is being discussed in 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 recognize the transfer of IPv4 resources resulting from a
partial or complete merger, acquisition, reorganization or relocation.
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 recognize the transfer or IPv6 resources resulting from a
partial or complete merger, acquisition, reorganization or relocation.
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 resulting from a partial or
complete merger, acquisition, reorganization or relocation.
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 and ensuring clarity on what
is allowed and what not.
The proposal makes clear that this may only happen, in case of Inter-RIR
cases, when both RIRs have a reciprocal policy.
Minimizing possible legal issues.
Disadvantages:
It could be considered that it can create further disaggregation,
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 when the transfer is requested.
In the Inter-RIR cases, coordination with the counter-part RIR is
needed, but this is already an ongoing activity because all the regions
(with the exception of AFRINIC), already have those mechanisms in place
(for both, administrative and technical aspects).
6. Impact on resource holders
------------------------------
None.
7. References
--------------
RIPE NCC:
https://www.ripe.net/publications/docs/ripe-682
ARIN:
https://www.arin.net/policy/nrpm.html#eight2
LACNIC:
https://politicas.lacnic.net/politicas/detail/id/LAC-2019-4/language/en
https://politicas.lacnic.net/politicas/detail/id/LAC-2019-3/language/en
https://politicas.lacnic.net/politicas/detail/id/LAC-2019-2/language/en
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