[Community-Discuss] Spearheading Internet Development in Africa / Late commentary on fee discussion

[S Moonesamy]

Dear Mr Loubser,
At 06:56 PM 29-09-2018, Coenraad Loubser wrote:
>I would like to add that we wholeheartedly support the current 
>recommendations - and that they do perhaps provide enough of a 
>platform to address the issue.

Thank you for the feedback on that section.

>The caveat is that, for an LIR, there is still the initial hurdle to 
>cross, that has not been "smoothed out", and which the suggested 
>provision can "smooth out" - which I would like to unpack more.

I'll comment below.

>Also, the addition of a clause such as the revenue-based one 
>proposed could potentially free up the board and/or CEO from having 
>to consider a number of individual applications - something that 
>could also be a restricting factor if the opportunities for such 
>reviews are spaced too far apart, or if they turn out to be too time 
>consuming. Ie. if an ISP is starting up, and can be convinced to get 
>its own ASN, but has to wait some months before it can actually get 
>it, it might just start without it and conclude that it's not really 
>necessary - and only revisit the benefits much later when truly 
>necessary - or never.

Is the time taken for getting approval for a discount a major factor 
for getting a new LIR to have its own ASN?  It looks like the other 
parts of setting up the operation could take more time; I am assuming 
that there isn't sequential processing.

>I suppose that there is another side to this is - and that is the 
>possibility for "fly-by-night" ASNs - or ones created to be used for 
>nefarious purposes and then discarded. although I am not sure if 
>there is a blanket control for the board to reject an any 
>application, is there? Then again, going through the trouble of 
>setting up a company, licensing it, getting the financials in place, 
>and applying for the concession, setting up peering - is likely 
>enough of a deterrent.

ASN requests are handled by the member services department.  The 
policies which are used to evaluate the requests are set by the 
Policy Development Working Group.  I could not think of a reason to 
be involved in a decision about the approval of such a request.  As a 
comment about "blanket control", the usual approach at Board-level is 
to see that there are adequate organizational processes.

Regards,
S. Moonesamy