Staff Assessment for AFPUB-2014-GEN-002-DRAFT-01 (was: Re: [rpd] New proposal - "Out-Of-Region Use of AFRINIC Internet Number Resources" (AFPUB-2014-GEN-002-DRAFT-01))

[Ernest]

Dear All,

Below are the points of interest that staff have noted in the policy
proposal Out-Of-Region Use of AFRINIC Internet Number Resources"
(AFPUB-2014-GEN-002-DRAFT-01):


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Chapter 2, Paragraph 1: "This policy allows up to 40% of Internet
number resources in use by a member to be outside the region..."

Staff Comment(s): The policy should be restricted to LIR allocations
and not End-User PI Space. There is no provision in the current
policies for AFRINIC staff to measure usage of End User (PI) space.
The staff's main basis of number resource usage assessment today is
by looking at PA assignments and sub-allocations registered by an
LIR in the WHOIS database as provided for in Section 9 of the "IPv4
Allocation Policy - AFPUB-2005-v4-001 at
http://afrinic.net/en/library/policies/126-afpub-2005-v4-001. This
method of registering usage in the whois db only applies to LIRs.
Staff recommends that this sentence therefore be changed to "This
policy allows up to 40% of Internet number resources in use by an
AFRINIC LIR member to be outside the region..."

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Chapter 2, Paragraph 2: “For the avoidance of doubt, the author does
not seek to prolong the lifespan of IPv4 with this proposal but
rather, to ensure that number resources allocated/assigned by
AFRINIC are used by legitimate members from the service region to
support their network operations, regardless of physical location”.

Staff Comment(s): Author should clarify about what is the intended
meaning of the words “legitimate members”. Staff shall otherwise
interpret it as “members in good standing”).

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Clause 3b: “Notwithstanding (3.a), the number resources used outside
the region at any given point in time shall not exceed 40% of the
total space in use by a member. Total space in use shall be
calculated as follows: if x be the allocation/assignment size; and
x-y the amount of space in use at time z, then 40% of (x-y) shall be
the ceiling)”.

Staff comment(s): The author should clarify further on the
formula/variables, by explicitly defining what “y” stands for.

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Clause 3c: "c. AFRINIC staff shall at their discretion, and using
whatever means are available, assess compliance.."

Staff comment(s): The staff's main basis of number resource usage
assessment today is by looking at PA assignments and sub-allocations
registered by the LIR in the WHOIS database as provided for in
Section 9 of the "IPv4 Allocation Policy - AFPUB-2005-v4-001 at
http://afrinic.net/en/library/policies/126-afpub-2005-v4-001. (We
may only take a step further when there are some doubt regarding
registered information).

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Clause 3f: “This policy shall apply to past, present and future
allocations and assignments made by AFRINIC”.

Staff comment(s): After the policy proposal is ratified and
implemented, there could be some existing members in breach of the
new policy. In-line with 6(d) of the RSA,  breach or non-compliance
with this policy should ultimately result in cancellation of the RSA
and consequent reclamation of associated resources. The proposal
should clearly state the time frame (duration) that should be
allowed for members in breach, and should also propose what steps
AFRINIC should take during this time frame in reaching out to
non-compliant members before revoking/cancelling their RSAs and
reclaiming their resources if they remain in breach after the stated
time period.

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Regards,
ernest.