[rpd] New Proposal - "Number Resources Transfer Policy (AFPUB-2015-GEN-001-DRAFT-01)"

Tue Nov 3 17:15:26 UTC 2015

On Tue, 2015-11-03 at 08:27 -0500, Owen DeLong wrote:
> I am neutral regarding this proposal at this time. My comments are
> intended strictly for informational purposes.
> 
> > On Nov 3, 2015, at 3:47 AM, Seun Ojedeji <seun.ojedeji at gmail.com>
> > wrote:
> > 
> > Dear Members,
> > 
> > We have received a new policy Proposal - "Number Resources Transfer
> > Policy (AFPUB-2015-GEN-001-DRAFT-01)"
> > 
> > Number Resources Transfer Policy
> > 
> > ID:              AFPUB-2015-GEN-001-DRAFT-01
> > Policy Name:     Number Resources Transfer Policy
> > Submitted:        29 October 2015
> > Status:        Under Discussion
> > Author:          Mark Elkins, mje at posix.co.za, Posix Systems
> > 
> > 
> > 1.0 Summary of the Problem Being Addressed by this Policy Proposal:
> > 
> > AFRINIC is the only Regional Internet Registry without a Transfer
> > policy for the movement of numbering resources - both in and out of
> > the Region. APNIC, RIPE NCC and ARIN have compatible Transfer
> > Policies, so it would seem wise to be compatible with them.
> > 
> 
> 
> This is not true… There are 5 regions and LACNIC also has no such
> policy at this time, though a couple of proposals have been discussed
> there without consensus so far.

OK - fair comment. 
AFRINIC is the only Regional Internet Registry without a Transfer policy
either in place or being discussed.
> 
> It is not clear to me that a lack of such a policy is in and of itself
> a problem or that such compatibility is necessarily in the interests
> of the AfriNIC region as a whole.

I believe it is in the interests of African Companies that wish to
expand out of the AFRINIC Region - by transferring their own space to
themselves in other Regions.
> 
> > 2.0 Summary of How this Proposal Addresses the Problem
> > 
> > The Policy solves the issue of an African organisation using space
> > in another Region. This Proposal currently does not attempt to
> > address Legacy Resources (IPv4 and ASN's) - that is resources that
> > are in the AFRINIC Region and were acquired before ARIN existed.
> > Legacy Resources may be moved out of the AFRINIC region and
> > redeployed freely. They may however be subject to the receiving
> > RIR's policies.
> > 
> 
> 
> The assertion made here may or may not be accurate. In the ARIN
> region, ARIN applies the same policies and procedures to the transfer
> of resources which were registered prior to ARIN’s inception as any
> other resource. There is no such thing as a “legacy resource”, only
> “legacy registrations”. To transfer a resource in the ARIN region, the
> recipient must sign a Registration Services Agreement and the
> transferred resources are not “legacy”.
> 
> 
> RIPE has taken a different approach.

In order to come up with this proposal, I took elements from both ARIN
and RIPE and then compared the hybrid with APNIC.
> 
> 
> I don’t know whether AfriNIC has made a decision on this subject
> either as an organization or as a community. Certainly a decision
> should be made if one has not already been made. However, any such
> decision should be made through the policy development process with
> proper and deliberate action by the community and the board, not by
> assertion in the ancillary text included with another policy proposal.
> 
> >                
> > 3.0 Proposal:
> > 
> > 3.1 The source entity must be the current rights holder of the IPv4
> > address resources recognized by the RIR responsible for the
> > resources, and not be involved in any dispute as to the status of
> > those resources.
> > A. Source entities outside of the AFRINIC region must meet any
> > requirements defined by the RIR where the source entity holds the
> > registration.
> > 
> 
> 
> It may be worth applying greater specificity/clarity here… “To
> transfer resources from another region, the source entity must comply
> with and are subject to the applicable source entity policies of the
> source RIR.”
> 
> > B. Source entities within the AFRINIC region will not be eligible to
> > receive any further IPv4 address allocations or assignments from
> > AFRINIC for a period of 12 months after a transfer approval, or
> > until the exhaustion of AFRINIC's IPv4 space, whichever occurs
> > first. This restriction is excluded if the Resource is transferred
> > to the same business entity operating in a different region. 
> > C. Source entities within the AFRINIC region must not have received
> > a transfer, allocation, or assignment of IPv4 number resources from
> > AFRINIC for the 12 months prior to the approval of transfer request.
> > This restriction excludes Mergers and Acquisitions transfers and
> > Transfers to the same business entity in a different region.
> > D. The minimum transfer size is a /24.
> > 
> > 3.2 - Conditions on recipient of the transfer:
> > 
> > A. The conditions on a recipient outside of the AFRINIC region will
> > be defined by the policies of the receiving RIR.
> > B. Recipients within the AFRINIC region will be subject to current
> > AFRINIC policies and sign an RSA for the resources being received.
> > C. Recipients within the AFRINIC region must demonstrate the need
> > for up to a 24-month supply of IPv4 address space.
> > D. The minimum transfer size is a /24.
> > 
> 
> 
> This proposal is, essentially, a combination of ARIN NRPM 8.3 and 8.4
> and as near as I can tell implements nearly identical effective
> policy.
> 
> 
> However, be aware that under this policy, entities in the RIPE region
> would be eligible to transfer AfriNIC resources based merely on the
> assertion of a plan to use 50% of the requested addresses within  5
> years. (RIPE’s current inter-RIR recipient policy). Once the resources
> have been transferred to the RIPE region there are almost no
> restrictions on the subsequent transfer of the resources.
> 
> 
> Under this proposed policy, I believe it would be trivial for entities
> in Africa to create temporary entities strictly for the purpose of
> exporting and monetizing AfriNIC resources 12 months after obtaining
> their initial resources.
> 
> 
> Whether this 12 month delay provides an adequate protection or whether
> any such protection is desirable is a matter I leave for the
> consideration of the community.
> 
> 
> Owen
> 
> 
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-- 
Mark James ELKINS  -  Posix Systems - (South) Africa
mje at posix.co.za       Tel: +27.128070590  Cell: +27.826010496
For fast, reliable, low cost Internet in ZA: https://ftth.posix.co.za
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