[AFRINIC-rpd] IPv4 Address Allocation and Assignment proposal

[sm+afrinic at elandsys.com]

Hi Guy,
At 01:08 24-01-2013, Guy Antony Halse wrote:
>The problem with this, as with other drafts, is that it assumes that the
>distinction between end user/end site and LIR is *completely* black and
>white.

I don't think that the distinction has to be completely black and white.

>Consider the following hypothetical situation:
>
>I run the internal network for a large, for-profit company.  We want to dual
>home, so we apply for PI address space.  At this stage we meet the above
>definition, and thus we apply as an "end site".  We have two ISPs, and
>everything is great.
>
>Some time later, perhaps as part of a corporate social responsibility
>programme, we lease a small NGO a single office in our building.  Although I
>use the word "lease" (because an agreement exists, and they are a separate
>legal entity), no money exchanges hands.  We do it because it is the right
>thing(tm) to do.
>
>The NGO then asks if we could possible give them Internet access.  We decide
>that because the impact will be minimal on our operations, we can do so.  We
>allocate them a subnet from our network, and use this to provide them with
>Internet access free of charge.  Again it is the right thing(tm) to do.
>They use less than 1% of our assigned address space, and virtually 
>no bandwidth.
>
>At this stage we technically no longer meet the definition above; we are now
>technically an LIR because the the space is not used internally any more and
>because we've made a single, very small sub-allocation.
>
>Assuming we're honest about it, in terms of AfriNIC's cost structures and
>this policy, things change:
>
>  - 8.5 requires I register the allocation with AfriNIC;
>
>  - I am now subject to the requirements of sections 8 through 10;
>
>  - The fees due to AfriNIC increase (outside the scope of this policy, but
>    relevant to the discussion).
>
>Our management decides that the additional cost and administrative burden
>this imposes it too onerous and cannot be justified.  It was fine when we
>were just running a UTP cable through the wall, but now we have to complete
>paperwork and spend (recurring) money.  Thus we have two choices:
>
>  a) lie (perhaps tacitly, by simply not telling) to AfriNIC.  This carries
>     the risk we'll be caught, and lose our assignment (per 6.1); or
>
>  b) cease providing the NGO with Internet access.
>
>Neither of these are desirable outcomes.

[snip]

>Thus I'm really opposed to any definition of "end user" or "end site" that
>doesn't allow /some/ flexibility for the grey areas.  I'm happy if this
>flexibility is formally qualified in policy -- appropriate restrictions
>include limitations on the amount of address space ("no more than 10%"),
>they type of organisation or relationship ("not-for-profit"), or whether or
>not this is how I make money or why I exist ("core business").

I am ok with not including any definition of "end user" or "end 
site".  IPv4 PI address space is covered by AFPUB-2006-GEN-001 
anyway.  Any limitation, restriction, relationship, etc. (re. case 
mentioned above) might have to be in AFPUB-2006-GEN-001.

As an off-topic comment, AfriNIC trained around 450 persons last 
year.  There are less than 10 persons who have commented on this 
proposal.  That doesn't provide a broad view of IP addressing-related 
problems across the region.  By the way, I am okay with objections as 
that is part of policy development.

Regards,
S. Moonesamy