[rpd] AfriNIC RSA & policy improvement

[Vladimir Kangin]

Dear Ladies and Gentlemen,
AFRINIC community,

Please allow me to tell you a 3 minute story before proposing some
suggestions for further discussion.

I would like to bring to your attention AGAIN, the case of IPTP
Networks. Being part of IPTP Holding PLC established in Cyprus. That's
200 miles away from Egypt for those who do not know where Cyprus is
situated. IPTP Networks is a member in good standing of LACNIC, APNIC,
ARIC and RIPE for quite some time and operates one of the largest global
networks across all of the continents.

In 2012 a decision was made by IPTP Holding PLC to invest and expand in
Africa. In order to be present in an AFRINIC region a company was
registered in the Seychelles. Our team has tried to secure initial
allocation of /22 for the star-up in Africa. However somehow,
communication had no progress. As a consequence last AFRINIC I decided
to visit AFRINIC in person in an effort to speed up the process.

As per AFRINIC advice we apply for /22 allocation in November 2014. We
clearly illustrated our plans and were given assurances that companies
such as IPTP Networks are welcome in Africa and that there will be no
issues in allocation.

During AFRINIC (roughly 7 months ago) we explained that we would like to
have /22 allocation for our project in Johannesburg and based on advice
from Arthur we obtained and provided a letter of intent as proof of our
agreements with Colocation and Network providers to deploy our POP in
Johannesburg.

However we have had no progress with allocation for a few months. At
this stage the AFRINIC team has informed our team that until we actually
deploy all equipment and network in Africa we would not get any
allocation. We were then given further assurances that as soon as our
presence in Africa was established there would be no further delays and
issues.

Based on this information IPTP Holding PLC has approved an investment
into the Johannesburg POP and as of April a full size POP has been
operating in Teraco JB1 datacenter. From that point we have endured a
monthly expense while our AFRINIC /22 allocation case kept being
delayed. We were repeatedly advised that in accordance with AFRINIC RSA
(due to so many fake applications) hostmasters are in the position to
request ANY documents from the applicants. Some of the documents that
have been requested are strictly confidential and we did our best to
obtain said documents from our vendors/providers together with the
appropriate letters.

However our documents were not accepted and Arthur continuously insisted
on documents that we cannot disclose. Having escalated it further we
have had a discussion with Medhvi and she has shown her full support for
the inadequate requirements of Arthur. Our position on this issue is
simple and open. We are happy to provide any reasonable proof of our
presence. We are OK with involving Terraco and Level(3) representatives
to provide required evidence too. The hostmasters reject these options.
At the same time Arthur is continually handling this case in a most
unfavorable way, taking a lot of resources from our team and delaying
the start date of operations in IPTP's Johannesburg POP.

We have large number of customers signed with IPTP Networks that are
waiting for the service to be delivered. This creates an additional
financial loss to IPTP Networks.

Medvi and Arthur have stated clearly that they cannot trust the letter
provided by Teraco (because there have been a number of forgeries) but
refuse to meet Teraco representative for confirmation. I therefore have
to admit that the policy is not sufficient and allows hostmasters to
make unilateral decisions at their sole discretion. 

Based on the unpleasant experience above I would like to humbly propose
few important changes to the RSA and policy:

Summary of proposal:

This proposal is to improve service quality and transparency of
AFRINIC's number resource service.

Proposal:
1. AFRINIC Shall define a clear time-frame for approval and escalation
whereby cases will be address to the management in a timely manner.
(It would allow to rectify the endless loop or let's say “ping pong”
cases in a constructive way)
2. AFRINIC shall simplify the extra-small and small allocation process
for companies entering the African continent. This can, for instance, be
copied from LACNIC whereby a company can be allocated a /22 on a basis
that it confirms its intention to start operations within 6 month of
assignment.
(Such treatment is certain to stimulate foreign companies' investment in
Africa, a fact that I am certain is welcome in this room) 
3. AFRINIC should publish standard documentary requirements for each
type of request for resource allocation.
(It is not enough to leave it up to the hostmaster's sole discretion to
request ANY information as is the case now in accordance with the
current RSA. This could allow the hostmasters to abuse the policy and
potentially pressure applicants for “bakshish”) 
4. AFRINIC should not store or request any marketing, business related
or basically non-technical information. For instance customer data,
marketing channels, marketing budgets etc.
5. AFRINIC allocation should be solely based on current policy, no other
factors other than policy should influence AFRINIC's decision on
processing allocation.
6. AFRINIC shall carefully select the hostmasters and monitor their
activities. In case of any suspicious activity the offender shall be
immediately suspended.
7. AFRINIC policy working group chair election should be conducted
independent from AFRINIC board nomination committee. Candidates should
be free of any requirements.

-- 
Best regards,
Vladimir Kangin
IPTP Inc Seychelles
Part of IPTP Networks
IPTP HOLDING PUBLIC LIMITED