[rpd] AfriNIC RSA & policy improvement

[Jean Robert Hountomey]

Vladimir, Jerome and Al,

Thank you for your patience with the AfriNIC Community. While I support the fact that it is not acceptable to delay a business
with unreasonable requests, I don’t think that AfriNIC's staff has a malicious intention.

Also I understand that something need to be done, and I fear that tackling it through a policy may not be the best option, it will add
delays from approval to adoption etc...



My suggestion (I second Adam) will be approaching AfriNIC's CEO. In addition I think your issue and the one from CloudFlare and many others can be resolved
if we ask AfriNIC to implement a Conflict Arbitration Procedure in the Membership documents.

A possible way would be to ask the Board to task the Council of Elders (defined in Article 16 of AfriNIC bylaws) to propose such a procedure and to nominate
Arbiters from AfriNIC region - and other Region - to serve as mediators in conflicts between AfriNIC and its members, and to evaluate the validity of such
requests.

I think RIPE NCC will be ok if we copy what they have in place and add our own part. (1).
I will also call for an Audit procedure to allow Arbiters to review allocation. RIPE NCC has a good sample.(2).

(1). https://www.ripe.net/publications/docs/ripe-613
(2). https://www.ripe.net/publications/docs/ripe-423

In addition, I see that you have also reported issues with the SLA. I don't know if AfriNIC's CEO is part of admin-escalate at afrinic.net
but we know him, and this can be reported to him.

Thanks.

Jean Robert.

On 6/5/15 10:10 AM, Jérôme Fleury wrote:
> 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
>>
>>
>> _______________________________________________
>> rpd mailing list
>> rpd at afrinic.net
>> https://lists.afrinic.net/mailman/listinfo.cgi/rpd
> _______________________________________________
> rpd mailing list
> rpd at afrinic.net
> https://lists.afrinic.net/mailman/listinfo.cgi/rpd