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

[Ernest]

Hi Douglas,

>>>> 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.

The (IPv4 allocation) policy clearly states measurement parameters
for PA space - by way of what has been registered in the whois db,
which is not the same for PI space and hence, there is no possible
"enforcement mechanism" we can base ourselves on for PI space purely
from the viewpoint of whois database records.

An 'enforcement mechanism' outside the policy is not possible in the
first place as it's the policy that should clearly determine (like
is the case with PA space) how to determine and measure the degree
of breach.

>>>> 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).

Noted - we'll effect the revisions.

>>>> 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.

We think it's not unreasonable for the proposal to suggest how much
time should be allowed for non-complying members to correct the breach.

Regards,
Ernest.