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

Owen DeLong owen at
Wed Nov 4 14:06:09 UTC 2015

Rather than a unidirectional modification as proposed, I would prefer to see a modification which delays the implementation of inter-RIR transfers until the AfriNIC free pool is completely empty.

In this way, you don’t have the asymmetry (which I will argue in the ARIN region should not be considered “compatible”), but you remove the risk which is the primary concern (mining of the AfriNIC free pool for off-continent utilization).


> On Nov 4, 2015, at 7:23 AM, Barrack Otieno <otieno.barrack at> wrote:
> Hello Colleagues,
> I would like to echo Andrews comments and support the Policy (with the
> amendments he has pointed out.) purely from a forwad thinking
> perspective
> Regards
> On 11/4/15, Andrew Alston <Andrew.Alston at <mailto:Andrew.Alston at>> wrote:
>> I for one support this policy, albeit with some modifications, for the
>> following reasons.
>> A.) As space depletion accelerates in Africa, we will get to a point where a
>> transfer policy that allows for transfers WITHIN Africa comes necessary.
>> Once the space is depleted a transfer policy will be required to stop the
>> transfers happening outside of policy and hence outside of any control of
>> AfriNIC.  Do not doubt they will happen with or without the policy, the only
>> difference is that with the policy, the whois databases and the rest at
>> least have a vague potential of being kept accurate
>> B.) While there will be a counter argument that space in AfriNIC will still
>> take an age to deplete, I point out that policy ratification in AfriNIC
>> takes a LONG time as we go through the iterations. (I point to the soft
>> landing policy which took YEARS to get ratified)
>> C.) I do not think that we should base this on African companies expanding
>> outwards, I’d be quite happy with a modification to this policy that
>> supported transfer of assets WITHIN the African region between African
>> players, and prohibits the transfer of space to companies outside of the
>> region.  Keep in mind, that as we currently stand, there is no policy
>> prohibition on using AfriNIC assigned space off continent (while there is a
>> proposal under discussion, this has been rejected twice so far), and hence
>> if the receiving entity is African, they can still, provided they can
>> adequately justify it, use the space where they need to use it.
>> I do think that an express prohibition on transfers outside of the region
>> (which is NOT the same as a restriction on genuine African entities using
>> their space outside the region for their own customers/purposes) may go a
>> long way to easing concerns raised so far.
>> Just my thoughts.
>> Andrew Alston
>> Group Head of IP Strategy
>> [cid:20CB5154-630B-4619-9207-C27E5328FF1A] <cid:20CB5154-630B-4619-9207-C27E5328FF1A]>
>> Sameer business Park, Block A, Mombasa Road. Nairobi, Kenya
>> T: +254 205000000 -  M: +254 733 2222 04 - E:
>> andrew.alston at <mailto:andrew.alston at>
>> From: Seun Ojedeji <seun.ojedeji at <mailto:seun.ojedeji at><mailto:seun.ojedeji at <mailto:seun.ojedeji at>>>
>> Date: Tuesday, 3 November 2015 at 10:47 AM
>> To: rpd <rpd at <mailto:rpd at><mailto:rpd at <mailto:rpd at>>>
>> Subject: [rpd] New Proposal - "Number Resources Transfer Policy
>> (AFPUB-2015-GEN-001-DRAFT-01)"
>> 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 <mailto:mje at><mailto:mje at <mailto:mje at>>, 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.
>> 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.
>> 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.
>> 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.
>> 4.0 Version History
>> 30 Oct 2015     AFPUB-2015-GEN-001-DRAFT-01 posted
>> Best Regards
>> Relevant Url:
>> 1. Policy Development process:
>> 2. AFRINIC Public policy meeting site:
>> ------------------------------------------------------------------------
>> Barry Macharia & Seun Ojedeji
>> PDWG Co-Chairs
>> Bringing another down does not take you up - think about your action!
> -- 
> Barrack O. Otieno
> +254721325277
> +254-20-2498789
> Skype: barrack.otieno
> <>
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