[rpd] AfriNIC RSA & policy improvement

[Jérôme Fleury]

Vladimir,

We (CloudFlare) are in the exact same situation as you:

- Company decides to make investments in Africa
- Company registered in Seychelles
- Unreasonable requests from hostmaster (he wanted the list of our 2
million domain names)
- allocation request started in October 2014, still no IP allocated
- wait times between replies are between 2 and 3 weeks
- the only way I found to get an escalation was to use Twitter - per
policy, admin-escalate at afrinic.net is unresponsive
- Plus adding a misinterpretation on the Anycast policy

This is delaying our deployment in Kenya and expansion in Johannesburg
where we already are.

I second your proposal.




On Fri, Jun 5, 2015 at 7:48 AM, Vladimir Kangin <v at kangin.org> wrote:
> 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
>
>
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