[Community-Discuss] Candidate for a Review on the Utilisation of INRs Allocated (was: Notice to all the legacy netblocks holders in AfriNIC)

[Ibeanusi Elvis]

Dear Sylvain,

Using RSA to manage resources is extremely dangerous, the RSA should not contain IP management clauses and any clause inside the RSA with the intention of managing the IPs, is invalid in nature. As those clauses have never went throughthe PDP and have never been a community approved document.

IP addresses are public resources that can only be managed though the PDP. The clauses that you have pointed out are not part of the CPM but rather the RSA—which makes them invalid.
 
As some other members have pointed out earlier, the CPM is originally designed to accommodate changes - that’s the exact reason why we have allocations and assignments. The lawyers clearly do not understand this and such misunderstanding went directly to the RSA without community review.
 
Moreover, if you look closely, if AFRINIC is required to re-evaluate the space it has issued in its entire history, not only it is an impossible mission, but I believe all of its member base will disagree and be angry about it.
I don’t think any space issued in 2005 for dial up service isstill used for dial up and I don’t believe any hosting provider in 2005 operates today, with the exact same customer composition and the same time as they got the space. Businesschanges and evolves, especially in the internet space and our industry is still at infancy. It is unrealistic to ask afrinic to upkeep and manage an entire continent’s IP usage, and afrinicwasn’t designed for it in the first place.
 
On the other hand, I believe that an accurate whois update already informs AFRINIC about change of usage which also lets lets the world know the “Whois”  who’s using the service.
As for violation of polices, CPM does define two type of violations:
1. Incorrect registration
2. Stockpiling.
 
And below I will give an exemple of an actual policy violation based on public data (see attached excel file) :
 
Seacom, a submarine cable provider without any publicallyknown individual end users base(for example FTTH customers) in 2014, was allocated /12 back then, and sincethen, in the past 7 years, it only used 39% of space range according to its assignement registration.
 
And none of its registrations are accurate, as defined by policy, an end user using more than 4 IPs must have theirname registered in their assignment, whereas seacom onlyregisters something like “Seacom-MPT-Customer”， in which in over a million space that Seacom has, it has never done a single accurate registration.
While I understand AFRINIC can not disucss individual member’s case in this public space, here are some questions to be thought after:
(1) Why is seacom being able to carry on with incorrect registration of their customer data and none usage of their space for 7 years? 
(2) Is any internal investigation being carried out on SEACOM for policy violation of section 5.5.1.9, 5.5.1.10 and 2.6 of the CPM? If not, is that fair to other members who received review?

(3) What is the reason for allowing a submarine cable provider, despite not having any individual end users back in 2014, be issued with such large space range in which was left unused for the past 7 years?

The Afrinic Consolidated Policy Manual reference:
2.4 of CPM (Allocation)
To "allocate" means to distribute address space to LIRs for the purpose of subsequent distribution.
 
2.6 of CPM (Assignment):
An assignment is an IP address block given by an LIR to its end-users for their own usage. To “assign” means to delegate address space to an ISP or End User for specific use within the internet infrastructure they operate. Assignments must only be made for specific purposes documented by specific organizations and are not to be sub-assigned to other parties.
5.3.2 of CPM (Registration Requirements):
All allocations, PI assignments, PA assignments, sub-allocations and other types of resource assignments will be registered in the AFRINIC database. Any unregistered resources will be considered invalid. The registration data (name, IP block/range, contacts, status, etc..) must be correct at all times. This is necessary to support network operations.
1. 5.5.1.9 of CPM (Utilisation)
Immediate utilisation of assignments should be at least 25% of the assigned space. After one year, unless special circumstances are defined, it should be at least 50%.

2. 5.2.1.4 of CPM (Conservation) :
To maximize the lifetime of the public Internet address space resource, addresses must be distributed according to actual need and on the basis of immediate use. Therefore, stockpiling of address space and maintaining reservations must, in general, be avoided.

5.5.1.10 of CPM (Reservations not supported):
End-users are not permitted to reserve address space based on long term plans. This violates the goal of conservation and fragments the address space when initial forecasts are not met. If an LIR wants to assign address space for customers, it must make the assignments from any unallocated or unassigned address space it currently holds. For the purposes evaluating allocation requests, space reserved by an LIR for other customers is considered unused.

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