[address-policy-wg] 2016-03 Discussion Period extended until 15 July 2016 (Locking Down the Final /8 Policy)

On Fri, Jun 17, 2016, at 23:48, Sander Steffann wrote:
> Two scenarios:
> 
> One
> - Someone opens up an LIR
> - They get their /22 (free)
> - They sell it off to another LIR for a profit
> 
> Two
> - That other LIR opens up a second LIR
> - They get their /22 (free)
> - They merge that new LIR with their old LIR using M&A

Three:
 - That other LIR opens up a second LIR
 - They get their /22 (free)
 - They can no longer apply "M&A" because the definition of "M&A"
 changed, and they have to do a regular transfer.

On a general basis, there may be reasons for which you have to proceed
with a regular transfer, other than "get IPs from NCC in order to sell
them".

It is my understanding, and please someone from RIPE NCC confirm or
infirm that in public, that M&A has "slightly" changed recently, and the
following operations are no longer M&A:
 - merging several existing LIRs having the same owner.
 - re-organisation of address space between the LIRs of a group.
 - purchasing a company but keeping the purchased company's legal entity
 (you accountant will give you good reasons for this; if you live in
 counties like France, your HR will give a few more reasons).
 - putting together resources of several entities within a group without
 proceeding with heavy legal and administrative paperwork.

> So what is this proposal blocking for new LIRs? Not buying space, not
> opening up a second LIR and getting that /22 from RIPE NCC. It only
> limits those LIRs from *selling* their /22 for profit.

For allocations prior to the unlikely application of the policy, it only
gives one shot for some business processes. For those made after that
hypothetic date, zero.
Unless someone from RIPE NCC (registration services or board preferred)
can infirm my understanding of recent M&A changes.

> currently violating the policy by requesting my /22 for the wrong reasons

Policy-wise, there are no "wrong reasons". If we decide to create them
however, there are two possibilities :
 - all allocations done *AFTER* the application of "wrong reasons
 policy" would be concerned. Not those done before.
 - in addition to the above, if we want to apply this to transferred
 space, *ALL* space transferred (regardless of the initial allocation
 date) should be concerned. 

> examples of issues, not some hand-waving like "this is disadvantaging new
> LIRs" without any explanation of how that exactly would work. Then we

See my comment above, under reserve of validation from NCC staff:
 - "old LIR" got a /20 on Aug 2012. They never needed to pay more than
 one membership fee
 - "new company #1" /22 on July 2015, another one on Dec 2015 (on a
 sister company) and anther one on June 2016 (another sister company,
 since "additional" LIRs is still not officially reinstated). Due to the
 new M&A rules, the ressources have to be transferred (regular transfer)
 in order for the LIRs to be consolidated. If 2016-03 goes "live" before
 July 2017, "new company #1" is stuck with 3 memberships forever for
 less space the "old LIR".
 - "new company #2" did similar things to "new company #1", just at
 different dates (2014/10 and 2015/09) and on the same legal entity. Not
 having had enough time to sort out the merger due to "have to run a
 business" they can no longer do the merge today and have to wait until
 2016/10, provided that 2015-03 does not go live by then. If for the
 same reasons the merger is left over until after 2016-03 goes live,
 they will also have to stay with 2 memberships forever.
 - "new company #3" which just got their /22 will face the risk of
 having to pay one membership per /22 forever.

--
Radu-Adrian FEURDEAN
fr.ccs