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[rpd] [Community-Discuss] Update to Resources review policy proposal

Andrew Alston Andrew.Alston at
Thu Nov 17 02:24:06 UTC 2016

Ok, Fair point that anyone can request an audit against anyone – now, lets ask some very specific questions which are again, valid concerns and objections that that in order to achieve the definition of consensus have to be addressed.

a.)     Why to the authors refuse to respond on the issue of allowing the entity to be audited know who requested the audit and under what grounds.  Why is there in effect prosecution without the chance to confront the accuser.

b.)    Why are the random choices limited to those categories, why should EVERY category not be subject to the same random picks – if you gonna apply it, let it apply globally

c.)     Why should AfriNIC publish the list of companies audited, especially if they are found to have clean audits - and not publish the name of the individual that requested the audit along with it

d.)    Why should entities that request an audit not be subject to automatic audit themselves

e.)    In the event that resource is held by an individual in their own right please explain to me how this entire policy would not put AfriNIC in direct violation of clause 4.d of the RSA, considering that any investigation into an individual could be classified as sensitive information under the Mauritian Data Protection act of 2004.

f.)      Please explain what would happen if an individual went through the routing tables, found 300 members that are not announcing space, and requested audits against all 300 of them simultaneously – which under the auspicious of this policy would be an entirely valid thing to do – and where the resources in a company that has less 1/6h of that number in terms of staff is meant to accomplish this

g.)     Please explain to me why anyone requesting an audit, and the audit is found to be frivolous upon investigation should be bare the entire cost of the work done – as is common in civil cases that are found to frivolous

h.)    Explain how AfriNIC is meant to deal with the situation where they may be under NDA with a particular organisation as a result of the fact that said organisation has demanded such in order to submit application information

i.)      Please explain how AfriNIC is meant to comply with its own public statements that information about an application is held confidentially – since disclosure of the outcome of an audit to have any meaning will mandate disclosing the original reason for request for IP space

Every single one of these points reflect lack of detail in this policy ad should be taken as a fundamental and valid objection to this policy unless adequately answered, and the objections shall be sustained unless they are answered fully and addressed directly.


From: ALAIN AINA [mailto:aalain at]
Sent: 16 November 2016 20:31
To: AfriNIC List <rpd at>
Subject: Re: [rpd] [Community-Discuss] Update to Resources review policy proposal

On Nov 16, 2016, at 8:14 PM, Andrew Alston <Andrew.Alston at<mailto:Andrew.Alston at>> wrote:

I actually disagree with this stance Mark,

I believe that if any member, irrespective of size, is subject to the policy, then policy should apply to ALL members.

I see absolutely no reason that if someone can request an audit on a medium or large member, then by the same token, a member holding a /24 should be subject to the same conditions.

Please read the proposal again

3.1 The reviews shall be based on compliance with the terms outlined in the RSA and Allocation/Assignment Policies.
3.2 The reviews cover all allocated/Assigned resources, but priority goes to IPv4 and ASN mappable to two-octet ASN.
And the 3.3 defines classes which cover all.


I point out at that the vast majority of space that is allocated and not in the tables is held by members who are holding /24s, 23/s and /22s, that analysis was clear.

Also, differentiating between end users and LIR's in this regard is also problematic.  If you are going to make people subject to audit under a policy which is rife for witch hunts and abuse - then make EVERYONE subject to it.  Anything else again, makes me question the real motivations behind this policy. I have to wonder if this policy not in fact designed so that people can demand audits on specific companies and individuals that they not prepared to name on this, and that the real motivation behind this policy is to give them grounds for a witch hunt rather than having anything to do with conservation or efficient use of resources.

I have these thoughts based on the fact that up until now, no one has shown ANY substantial evidence of resources being used outside of policy, nor have I seen any willingness to put proper protections in place, nor have I seen pre-emptive moves by supports of this policy to justify their usage publically when questioned, despite supporting a policy that if applied to them would mandate that AfriNIC makes public disclosure of the findings of investigations - but curiously enough - I then discover that those same people are not subject to their own audit policy because of their membership category.

I'm not saying anything dodgy is going on here for certain... but I will say that I am beginning to openly question the motivations for the policy and until proven wrong by the authors through proper substantiated evidence, those doubts will linger in my  mind, and every member of this list looking at policies like this, should take a long hard introspective look and ensure they understand the true motivations behind the document.


-----Original Message-----
From: Mark Elkins [mailto:mje at]
Sent: 16 November 2016 18:40
To: rpd >> AfriNIC Resource Policy <rpd at<mailto:rpd at>>
Subject: Re: [rpd] [Community-Discuss] Update to Resources review policy proposal

What was the motive for this policy?

| stockpiling and non-efficient use

What did it go out to fix in the first place?

A thought in the back of my head is this would be used to mainly audit people with lots of space?

| 3.3 Classes of review: Members to be reviewed shall be selected
| according to the following classes:
| 3.3.1 Random: The member is chosen by AFRINIC at random between
| members of the following categories:
|    Medium and above
|    IPv6-only Large
|    EU-AS

So we ignore smallish LIR's
but not smallish EU's
I think less than medium EU's should also be ignored.
Do we really need to include IPv6 today?

| 3.3.2 Selected:
| A member is selected because of an internal report or due to a lack of
| contact between the AFRINIC and the member.
| 3.3.3 Reported: Here, members are reviewed either because:
| They have requested the review themselves or There has been a
| community complaint made against them
|   that warrants investigation.

If people report "out of business" businesses with IP Resources, no problem.

However, it appears that anyone (including a non-member) can call for a review of a large member. Still sounds like an excuse for a witch hunt.
This needs to be much better worded control.

1 - Only Members (preferably in "Good Standing") can file a report.

2 - They can only do so if they are within 50% of the size (in contested address space) of the Member they are calling out. Perhaps a "Group Action" can be established to achieve this requirement.

3 - They can expect to be audited themselves - especially if the requested audit comes out clean.

4 - On the other hand, the AFRINIC Board can always call for an Audit (I trust them).

Anyway, where do I find the complete current Draft? I've been looking at:-

On 16/11/2016 12:43, Andrew Alston wrote:


I have a hypothetical question – and it will become a lot less
hypothetical once I’ve run the numbers which I’m currently doing.

Let’s say we implement this audit policy – and then – because we have
to act consistently – we act against every member who is not
announcing space because they cannot justify not announcing it – and
we terminate their membership.

Are the authors of this policy and those supporting it prepared to
bear the cost of the fee increases that would be necessary to back
fill the loss in revenue that would effectively bankrupt AfriNIC?
Running through the preliminary statistics – firstly the auditing
process would be immensely expensive in HR cost – secondly –
termination of members that aren’t “legitimately” announcing space by
rough calculations could cost AfriNIC in excess of 15% of its revenue
by the latest numbers available in the financial reports and
correlating the unannounced space that is allocated with the billing file.

Now, some would argue that is all the more reason to implement the
audit policy – but here is a wake up call – the space you would
recover in that call on those calculations – amounts to less than 10%
of space that AfriNIC has allocated legitimately since May – so
effectively, for the gain of looking tough and being rigid, we may end
up bankrupting the organisation while recovering potentially a /15 worth of space.
Alternatively, from any logical business perspective – that money
would have to be recovered from the members who are legitimately
announcing space – because it certainly can’t just disappear.

So, has anyone ACTUALLY thought through the implications of this
policy?  I remain firmly opposed.


*From:*Dewole Ajao [mailto:dewole at]
*Sent:* 16 November 2016 12:52
*To:* sergekbk <sergekbk at<mailto:sergekbk at>>; Arnaud AMELINA
<amelnaud at<mailto:amelnaud at>>; rpd >> AfriNIC Resource Policy
<rpd at<mailto:rpd at>>; General Discussions of AFRINIC
<community-discuss at<mailto:community-discuss at>>
*Subject:* Re: [Community-Discuss] Update to Resources review policy

I think all policies (if we really intend to implement them) must be
clear and leave no room for variable interpretation as ambiguity will
put additional burdens of interpretation on staff.

If the community's preference is for the 24-month window to become
invalid on allocation/assignment of new resources, then the policy
(proposal) should state it clearly; If on the other hand, the
intention is for the 24-month window to stay in place come-what-may,
it's better for the policy (proposal) to be explicit about it.

Please see below, additional questions for the community to consider.
Hopefully, they can be discussed and the authors can (if they so
choose,) take the inputs from the community into their modified proposal.

3.3.2 Selected:

A member is selected because of an internal report or due to a lack of
contact between the AFRINIC and the member.

Q1. Do we presently have an existing (effective) structure (apart from
billing) that measures degree of contact with members?
If there is no agreed means of measuring the degree contact, we need
to define degrees of contact so that "lack of contact" (as referred to
in the proposal) can be measured objectively.

/Perhaps as a first step for ensuring regular contact without using up
too many resources, this proposal might want to borrow a leaf from
RIPE's Assisted Registry Check (ARC). See

/Basically, the RIR does a consistency check on members' Registry,
Resource, and Route/rDNS information and then sends emails to the
contacts on file showing their view. They then schedule a telephone
call to work with the member and fix any identified issues. /

/My understanding from RIPE is that these non-invasive checks
sometimes reveal issues that may warrant more detailed investigation.
The primary model is by random checks but done in a manner that checks
every member at least once in 3 years (given the size of RIPE). They
also have ARCs that are initiated as a result of information received
from the member or third parties. /

Q2. Can reachability/cooperation of a member for such a consistency
check-and-fix activity as described above be used to measure the
degree of contact?

Q3. Given the fact that time taken for consistency checks are more
predictable, can these be implemented as a preliminary step in
addressing the "lack of investigation" problem as well as the concern
about taking up much of members' and/or AFRINIC hostmasters' time?

(with apologies for continuing the cross-posting between RPD and

On 15/11/2016 20:18, sergekbk wrote:

   Hello Dewole,

   Thanks for this comment.
   The limit of 24 months applies to a member based on ressources
   portfolio.  If  the portfolio  changes with new allocation,   member
   can be audited  anytime on the new ressources if required.

   Is this clear enough or shall we make  it explicit  ?

   Kind Regards.

   */Serge Ilunga/*

   */Cell: +243814443160/*

   */Skype: sergekbk/*


   -------- Original message --------

   From: Dewole Ajao <dewole at<mailto:dewole at>> <mailto:dewole at>

   Date: 11/15/2016 11:38 (GMT+01:00)

   To: Arnaud AMELINA <amelnaud at<mailto:amelnaud at>> <mailto:amelnaud at>,
   "rpd >> AfriNIC Resource Policy" <rpd at<mailto:rpd at>>
   <mailto:rpd at>, General Discussions of AFRINIC
   <community-discuss at<mailto:community-discuss at>>
<mailto:community-discuss at>

   Subject: Re: [Community-Discuss] Update to Resources review policy

   Thanks for working to apply the community's input to your proposal,

   To test the proposed re-wording, consider the following sequence of

   Member XYZ initiates self-requested review;
   Review is completed by AFRINIC in X weeks;
   After review, Member XYZ applies for "large chunk" of number resources;
   Member XYZ receives "large chunk" of number resources in say 60 days;
   Member XYZ happens to make some unacceptable use of (previous or
   new) number resources and it somehow becomes known to the community;
   Regardless of convincing evidence, Member XYZ cannot be subjected to
   a review until 24 months have elapsed since the last review.

   Is this a design feature or a bug?



   On 15/11/2016 10:48, Arnaud AMELINA wrote:

       Hi community !
       Following, recent discussions and in accordance with text
       proposal from Owen and others contributors, authors propose this
       as replacement to the section 3.3.3

       -'---old version---''

       3.3.3 Reported: Here, members are reviewed either because:

       a. They have requested the review themselves or
       b. There has been a community complaint made against them that
       warrants investigation.

       ----new version-----

       3.3.3 Reported: Here, members are reviewed either because:

       a..They have requested the review themselves or
       b. There has been a community complaint made against them that
       warrants investigation. Complaints shall be backed by evidence
       and AFRINIC  staff  shall evaluate the facts as appropriate to
       conduct the review. However this review is not applicable to a
       member  on which a full review has been completed in the
       preceding 24 months.




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