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[rpd] [Community-Discuss] Update to Resources review policy proposal
Andrew Alston
Andrew.Alston at liquidtelecom.com
Thu Nov 17 13:25:34 UTC 2016
Just to add to this as well –
The only authorized “transfers” right now are through mergers and acquisitions.
If a company goes bust – the space should be returned to AfriNIC – no question about it.
However, if a company ceases to exist due to an A&M, at the time of acquisition under current rules space can be transferred from the original holder to the new parent company – and consolidations such as this are well document and there is precedent for them. I’ve been through this process several times and I can state categorically that the checks and balances in place on it are stringent and it is properly executed.
Andrew
On 17/11/2016, 13:25, "fransossen at yahoo.com" <fransossen at yahoo.com> wrote:
Hi,
Just to add a bit to Andrew's excellent points.
1)
Any audit should be performed to ensure that a resource holder:
A) that the resource holder exist/still exist.
If the initial set of information was fraudulent, there is no fix, as the initially provided docuemtna were false, no fix possible.
If the company name is incorrect, it can be fixed if it is out of date registrations, undeclared company take over or name change.
If the company does not exist anymore and with no legal successor, resource must be returned to the AFRINIC.
B) that the resource holder is policy compliant.
By far the easiest, review the data registration with the resource holders, confirm all OK, if needed request assignment request forms or sub-allocation request forms, validate the data, educate the LIR that this should be done before, not after the facts.
So just assisting the LIR in being compliant and provide some education.
Overall, the simple mention that resource holders MUST be policy compliant and RSA compliant would be enough, no need to go into the specifics of the breaches, the policies define what is to be compliant, not the audit document.
The above can only be done on adhoc basis, it would be unrealistic to ask the AFRINIC to currently audit all resource holders, checks are currently performed during additional allocation requests, bills are paid every year, it covers most of the needed checks.
Is a periodical review of all resource holders really that needed?
If someone was to report an obvious policy violation, it must be investigated, which I believe is already the case today.
2)
> 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
This implies that smaller organisation do not have to follow policies, or that the policies treat small and large organisations differently.
All resource holders must be treated equal, this actually removes neutrality in the audit system defined by this policy proposal.
3)
> 3.4 In case of non-compliance and if evidence has been established in accordance with the non-exhaustive list below:
> Unjustified lack of visibility of the resource on the global routing table.
There are many reasons for address space not to be visible, change of business model/change of network topology.
If an LIR has unused allocations, they cannot request new ones, so this is actually a no issue.
And how would this actually consists a policy violation?
> Breach of AFRINIC policies.
Fair enough, it should be on top of the list though.
> Breach of the provisions of the registration service agreement or other legal agreements between the organization holding the resource and AFRINIC.
Fair enough, again should be on the top and merged with the line about the policies to be followed.
> Evidence that an organisation is no more operating and its blocks have not been transferred.
If an organisation does not exist anymore, its resources must be returned to the AFRINIC free pool, not transferred.
This policy would authorise transfer of resources from defunct companies!
> Unauthorized transfers of resources.
Can you define what is an "Unauthorised transfer"?
For an LIR:
You can have unauhtorised assignments and sub-allocations, both are policy violations, but not resource transfers, what would be an unauthorised transfer?Since the allocation is still registered to them and they can assign and sub-allocate, as long as the LIR still exist as a legal entity, otherwise, if the LIR does not exist and the resources must be returned.
For an end user:
It would mean they have handed over their assignment to a third party, rendering the initial assignment criteria either invalid if the assignment is not used for the same network/purpose any longer, or is just a company name change away to be fixed if the assignment is still used for the same network.
And there are no framework for transfers.
4)
Finally, would this policy proposal be taken as a transfer policy as well?
Transfers are mentioned twice, while the transfer policy is still being discussed.
Cheers,
David Hilario
On Thursday, November 17, 2016 4:28 AM, Andrew Alston <Andrew.Alston at liquidtelecom.com> wrote:
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.
Andrew
From:ALAIN AINA [mailto:aalain at nsrc.org]
Sent: 16 November 2016 20:31
To: AfriNIC List <rpd at afrinic.net>
Subject: Re: [rpd] [Community-Discuss] Update to Resources review policy proposal
On Nov 16, 2016, at 8:14 PM, Andrew Alston <Andrew.Alston at liquidtelecom.com> 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 http://www.afrinic.net/en/community/policy-development/policy-proposals/1827-internet-number-resources-review-by-afrinic
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.
—Alain
>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.
>
>Andrew
>
>
>-----Original Message-----
>From: Mark Elkins [mailto:mje at posix.co.za]
>Sent: 16 November 2016 18:40
>To: rpd >> AfriNIC Resource Policy <rpd at afrinic.net>
>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:-
>
>http://afrinic.net/en/community/policy-development/policy-proposals/1827-internet-number-resources-review-by-afrinic
>
>
>
>On 16/11/2016 12:43, Andrew Alston wrote:
>
>
>So,
>>
>>
>>
>>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.
>>
>>
>>
>>Andrew
>>
>>
>>
>>
>>
>>*From:*Dewole Ajao [mailto:dewole at forum.org.ng]
>>*Sent:* 16 November 2016 12:52
>>*To:* sergekbk <sergekbk at gmail.com>; Arnaud AMELINA
>><amelnaud at gmail.com>; rpd >> AfriNIC Resource Policy
>><rpd at afrinic.net>; General Discussions of AFRINIC
>><community-discuss at afrinic.net>
>>*Subject:* Re: [Community-Discuss] Update to Resources review policy
>>proposal
>>
>>
>>
>>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
>>https://www.ripe.net/manage-ips-and-asns/resource-management/assisted-
>>registry-check/
>>
>>/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?
>>
>>Regards,
>>Dewole.
>>(with apologies for continuing the cross-posting between RPD and
>>Community-discuss)
>>
>>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/*
>>
>> */R.D.Congo/*
>>
>> -------- Original message --------
>>
>> From: Dewole Ajao <dewole at tinitop.com> <mailto:dewole at tinitop.com>
>>
>> Date: 11/15/2016 11:38 (GMT+01:00)
>>
>> To: Arnaud AMELINA <amelnaud at gmail.com> <mailto:amelnaud at gmail.com>,
>> "rpd >> AfriNIC Resource Policy" <rpd at afrinic.net>
>> <mailto:rpd at afrinic.net>, General Discussions of AFRINIC
>> <community-discuss at afrinic.net>
>><mailto:community-discuss at afrinic.net>
>>
>> Subject: Re: [Community-Discuss] Update to Resources review policy
>> proposal
>>
>>
>>
>> Thanks for working to apply the community's input to your proposal,
>> Arnaud.
>>
>> To test the proposed re-wording, consider the following sequence of
>> events:
>>
>> 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?
>>
>> Regards,
>>
>> Dewole.
>>
>>
>>
>> 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.
>>
>> Regards.
>>
>> Arnaud.
>>
>>
>>
>>
>> _______________________________________________
>>
>> Community-Discuss mailing list
>>
>> Community-Discuss at afrinic.net
>><mailto:Community-Discuss at afrinic.net>
>>
>> https://lists.afrinic.net/mailman/listinfo/community-discuss
>>
>>
>>
>>
>>
>>
>>
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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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