[Community-Discuss] Notice to all the legacy netblocks holders        in AfriNIC

[JORDI PALET MARTINEZ]

Hi Widjane,

 

Responding below in-line …

 

 

 

El 12/2/21 18:06, "Wijdane Goubi" <wijdan.goubi at gmail.com> escribió:

 

Hello Jordi,
 
So the thing is that, since all of the 5 RIRs have transfer policies (regardless whether they are intraRIR or interRIR), and since no one has ever applied space 

 

[Jordi] This is not correct. In the PDWG I’ve presented several times stats about the transfers that have been happening since a few years.

 

for transfer in the history of RIR, then by the very definition of the transfer policy, the change of purpose is allowed. If in some region there is some old and 

 

[Jordi] This is an agreement of the community (in some RIR communities): Policies don’t allow you to change the “usage” (for example you want to use more of the 50% of the space out of the region), however, instead of returning it, because others need it (at least when speaking about IPv4), we allow it to be transferred HOWEVER the new resource-holder MUST pre-qualify to receive the space following the existing policies (in the destination RIR). I will agree that in a ideal world, instead of transfers, we will just be honest, return the space that we no longer use to the RIR, so it can be allocated to others that demonstrate the justified-need. However, that will not solve the unbalance between different regions, and the transfers resolve that. Some regions have more legacy or more IPv6 deployment, which means that they are happy to (get some money) and transfer it to other regions.

 

obsolete policy text that forbids change of purpose for usage, then those should be considered invalid because they are directly contradicting the newer 

 

[Jordi] I disagree here. It is not about obsolete policies, it is about different cultural and business visions, tied to different timings. In the end, my experience shows that most of the RIR policies tend to converge, may be not with a 100% same wording or intent, but very close. Again, I will probably prefer that those usage changes are less restrictive, but it is very difficult to make a policy that has the right balance for all the community participants, especially in that specific topic and even more in regions that have a smaller Internet footprint vs others more advanced: it is completely understandable, because you may think that the resources that you will need in that region may go away (even if that’s not the case as IPv6 deployment in other regions is progressing faster).

 

policy text (transfer policy). Also, while a proper policy update is preferred in those situations, it is not necessary, since the later policy text always wins over the old one, as the newer one represents better the current community needs and wishes.

 

[Jordi] No, they are different policies: we still need a “justified need policy” and a transfer policy. Otherwise, you could transfer the space to someone that only want it to stockpile and do business, and this is not the purpose, because that will be really bad for the global Internet. So justified need policies try to avoid that as much as possible.


 
Besides, change of purpose for usage is allowed in the current AFRINIC policy text. There is not even an obsolete old policy text in AFRINIC’s CPM that prevents LIR making their assignment for a different purpose, it only mentions the sub-allocation, which is a totally different thing. So basically, change of purpose for usage is always allowed in the AFRINIC region.

 

[Jordi] I read the CPM differently. In the case of IPv4, for example, section 5.4.6.2 states that the AFRINIC resources are for this service region and only can be  used outside for connectivity back to the region. Before the existence of that policy, it could be unclear if you can use the resources outside, but not since it was ratified.


 
In fact, the design of IP address policy did have the change of purpose in mind, that is the very reason why we have two distinct definitions of  "allocation" and "assignment", LIR gets allocation, then makes assignment for each specific user case, while the allocation is for general purpose, and you need to make the assignment inside the allocation for each user case to the end users. The Allocation stays with LIR, while the Assignment comes and goes as the user case existed or not. If change of purpose is not allowed, then there is absolutely no reason to distinguish them. AFRINIC should make assignment to each LIR then evaluate every time the user case changes which is quite impossible and impractical. As an example, if I made /23 for one web hosting customer and then the customer leaves, I will need to go through an entire application process again just because the same server goes to a VPN customer, and this doesn’t happen anywhere in the world, and currently not with AFRINIC. Allowing LIR to freely manage its space usage within the allocation is the very core design of IP address policy.

 

[Jordi] Nothing to object here, but still if you have documented (justified) in the original allocation request to AFRINIC a specific usage, for supporting, let’s say 1 million customers, and now you only have 100.000 customers, the justification becomes invalid. That’s why transfers come in place. Of course, you still can instead of using the transfer, return the space to AFRINIC, but you can’t just “stockpile” the addresses, or use them out of the region. Remember also that the bylaws allow the membership (section 6.1) to those based in the region and providing services in the region. So if you stop providing services or go away from the region, the membership can only be sustained if it is approved by the board or the membership. Finally, the RSA section 4, state that the conditions of the service are “solely for the purpose for which it was requested” so depending on *what* you requested, you may be acting against the original purpose if you change your business. I agree that in some sense this should be only part of the CPM, but the current situation is that the RSA also have that normative text.


 
Moreover, this is the exact reason why RSA is so badly written and shouldn't contain any resource management clause. The lawyers do not understand the very concept of Allocation and Assignment, let alone distinguishing between them. Therefore, allowing lawyers texts to manage community resources is not only illegitimate, but also lacks of needed technical understanding of addressing to properly write it, that is why we now have an RSA which is full of invalid IP management clauses and contradiction to the policy itself, which needs to be fixed at some point of time. Not to mention that allowing lawyers to manage the resources defies the very foundation of the bottom up process.

 

[Jordi] Yes, I just said it … probably the RSA needs a lot of tidy-up … and not just by lawyers!

 

Le jeu. 11 févr. 2021 à 20:34, JORDI PALET MARTINEZ via Community-Discuss <community-discuss at afrinic.net> a écrit :

Hi Widjane,

 

I agree with you in some of the points, but not in all them.

 

1.       Policies among the RIRs aren’t exactly the same. They tend to converge with the time, but not always are 100% the same.

2.       In fact, in some RIRs, right now, if you asked for resources and provided documents about what will be the usage and you change usage, you’re under lack of compliance. Note that we aren’t talking about business grow. For example, a very simple on, let’s suppose you got resources for an organization (assigned resources) and now you want to provide Internet services to others, that will be against policies, in all the RIRs. Another example, if you got resources in some RIRs you can’t use them to provide services outside of that region (at all, example AFRINIC, or depending on the % example LACNIC, it depends on the RIR).

3.       I can agree with your that this is not right in many situations and policy should allow it. However, there are technical issues about allowing that freely, not just policy issues (and sometimes the policy issues, in fact, happen because technical issues).

4.       AFRINIC is the only RIR, at the time being, that has not adopted (ratified and even less implemented) a policy proposal for Inter-RIR transfers. However, even in most of the RIRs, the allowed transfers are only for IPv4.

5.       I will love that we could make policy changes in a more dynamic way, but specially in AFRINIC, it is being too slow.

 

Regards,

Jordi

@jordipalet

 

 

 

El 11/2/21 20:01, "Wijdane Goubi" <wijdan.goubi at gmail.com> escribió:

 

Dear community,

Technically speaking, if a change of the nature is not allowed (as claimed by some) this doesn’t make any technical sense at all as there are consensus among several RIRs to allow inter RIR transfer and also allows intra RIR transfers. 

The logic adopted that the change of nature is not permitted doesn’t sit well with the established sections of the policies adopted and used. In fact, the logic will bar and limit the ability for an organization to grow and expend its services. 

This imposition will also burden the member to go through unnecessary bureaucratic demands and expectations whereas the matter could easily be resolved. The policy and understanding of business nature needs to be as dynamic as the internet is!

The internet grows and evolves from one form to another, so should the policy. 
In fact, RIR never bothers or care with how the space is being used for.

A post from years ago (https://lists.afrinic.net/pipermail/rpd/2017/007222.html ), from both ARIN and RIPE explained that once the space is issued, their only concern is to ensure accurate registration.

The video and the section where both ARIN and RIPE NCC are speaking can be found on the following link: https://youtu.be/XBv44KAgFVQlist=PLLJRUWAm1GCZAGzqiCzX2CRU7oqLDC9e5 

At or around 08:27:50, Andrea Cima from RIPE NCC explains that their reviews are called “ARC”, and it is to keep in touch and keep the data up to data, registry data, that is the contact details and so on. Investigation, that is the part of the “fraud”.

Whereas, at or around 08:29:50, Leslie from ARIN explains the scope of their policy, they only audit in fraud cases and only deregister in case of fraud.

Neither the RIPE NCC or ARIN does a re-evaluation of the resources and questions on how the LIRs are currently using their resources.

There is a global consensus on how spaces are being used currently—as long as the allocation process was justified and registration is actual, RIR does not care about its current usage.

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