[AFRINIC-rpd] IPv4 Address Allocation and Assignment proposal

[Owen DeLong]

On Jan 29, 2013, at 02:02 , sm+afrinic at elandsys.com wrote:

> 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.

If the distinction is not black and white, it becomes very difficult to make it
a consistent shade of gray. Policy that is not black and white tends to be
subjective in its nature and makes it very difficult for AfriNIC staff to apply
it consistently.

> 
>> 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.
>> 

Technically, at this point, you have become an LIR, IMHO. However, I accept that
there shouldn't necessarily be a fee implication to doing this. How about something
like this:

End-User -- An organization which does not delegate resources to other external
organizations and therefore does not generate SWIP or other sub-delegation or
re-assignment records.

Casual LIR -- An organization which is primarily an end-user, but may, in the course
of its operations, provide internet access and/or resources to a small number of other
organizations. An LIR qualifies as a casual LIR if it delegates less than 10% of its
total address holdings or if it provides connectivity and number resources to fewer
than 5 external organizations. Such an organization is subject to all LIR policies
regarding record keeping, but shall be billed at the end-user rates unless they
inform AfriNIC in writing that they wish to be treated as a full LIR.

Full LIR -- An organization which delegates number resources to external organizations,
but which does not qualify, or, has elected not to qualify as a Casual LIR.

I believe this gives us a sufficiently black and white definition for consistent
application of policy while still allowing for the type of utilization you have
described above.

>> 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.
>> 

True.

>> 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;
>> 

Which is valid, IMHO.

>> - I am now subject to the requirements of sections 8 through 10;
>> 

As should be the case.

>> - The fees due to AfriNIC increase (outside the scope of this policy, but
>>   relevant to the discussion).
>> 

Which I agree could be adressed. What do you think of the above proposal?

>> 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:
>> 

Well, failing to do the paperwork has implications for the community. Also, your
management should consider the risk that the actions committed with those
addresses could reflect on your organization even though you have given up
direct control of the addresses. Having this fact recorded is somewhat of a
liability and/or image shield for your organization. Technically, the paperwork
is pretty small.

>> 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
>> 
Undesirable for a number of other reasons, as well. (see my previous
paragraph).

>> b) cease providing the NGO with Internet access.
>> 

Unfortunate. However, I thin the fee issue is the bigger barrier than the
paperwork, right?

>> Neither of these are desirable outcomes.
> 

Agreed. Let's try to find a cooperative solution.

Finally, I chose 10% as a rather arbitrary number. I'm actually fine with
any value between 5 and 25, whatever the community thinks is most
appropriate. The number 10 organizations is also an arbitrary placeholder.
I think any number ≤20 is probably acceptable here and welcome
input from the community.


> [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.
> 

You kind of need a definition here of end-user and end-site, since they are referenced in regard to reassignments.

> 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.
> 
+1

Owen

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