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

[Douglas Onyango]

Hi Ernest,
On 16 October 2014 11:54, Douglas Onyango <ondouglas at gmail.com> wrote:
> Hi Ernest,
> On 2 October 2014 15:04, Ernest <ernest at afrinic.net> wrote:
>> We are expecting some feedback from you regarding the staff's
>> assessment of your proposal.

Sorry for the delay. My comments are inline:

>>> 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..."

 I think the issue the policy is trying to resolve is as valid for PA
 as it is with PI space. I am reluctant to remove this clause just
 because AFRINIC doesn't have an enforcement mechanism at the moment. I
 would challenge AFRINIC to revert if PI space wouldn't be vulnerable,
 else an enforcement mechanism should be sought in parallel, but
 outside this policy.

>>> 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").

 I have removed "legitimate" and revised the statement to read: ...he
 seeks to ensure that number resources allocated/assigned by AFRINIC
 are used by members from the service region to support their
 legitimate network operations, regardless of physical location

>>> 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.

 Done. Now reads: Total space in use shall be calculated as follows: if
 x be the allocation/assignment size; and y the amount of space in use
 at time z, then 40% of y shall be the ceiling).


>>> 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.

 I am averse to the idea of a separate enforcement mechanism as it may
 create disharmony with already existing RSA breach procedure. I need
 this to be uniform and consistent with the already existing one. If
 the status quo is found to be wanting, I would rather it be revised in
 uniform and appropriate manner.

 Regards,
 --
 Douglas Onyango, PRINCE 2, ITILv3
 UG: +256 776 716 138 | NG: +234 706 202 8375



-- 
Douglas Onyango, PRINCE 2, ITILv3
UG: +256 776 716 138 | NG: +234 706 202 8375