[rpd] Re: Staff Assessment for AFPUB-2014-GEN-002-DRAFT-01

[Ernest]

Hi Douglas,

We are expecting some feedback from you regarding the staff's
assessment of your proposal.

Our comments were sent earlier below for your perusal.

(Comments from others are of-course welcome too)

Regards,
Ernest.

Ernest wrote thus on 9/3/14, 12:04 PM:
> 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):
> 
> 
> ========================================
> 
> 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..."
> 
> _________________________________________
> 
> 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”).
> 
> _________________________________________
> 
> 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.
> 
> _________________________________________
> 
> 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).
> 
> _________________________________________
> 
> 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.
> 
> ========================================