[rpd] Proposal Update received: Internet Number Resources Review by AFRINIC

[fransossen at yahoo.com]

 Hi,


 On Sunday, November 20, 2016 1:50 PM, Seun Ojedeji <seun.ojedeji at gmail.com> wrote:
 > Hi again,> For completeness, I thought I should add rationale for the suggested changes:> 1. A policy should NOT be to directly name and shame but to encourage and ensure usage of allocated resources based on initial needs.> 2. There are years when report may not be applicable simply because no review was required/necessary.> 3. Anyone blowing whistle must do so based on log of proof for certain period of time i.e the whistle blower must have done significant > homework in order to better utilise staff resource.> 4. It's important to ensure privacy of members (both the accused and the accuser) so this doesn't turn to a hunting game.

I really fail to see how this discussion started to focus on "witch hunting" and whistle blowers?AFRINIC policies are to be followed by LIRs and END USERs, AFRINIC is there to enforce the policies in place and educate those users end of story.
Regular reviews is a good idea in itself, which I believe is already done during additional resource requests and by having the members paying their bills they mostly confirm they are still in existence. 
If needed this can even be coupled with sending a certificate of good standing from the chamber of commerce or from company registry where they are registered at to the AFRINIC once a year, during the billing season.
Anyone noticing dead companies in the AFRINIC registry should notify the AFRINIC about them, so they can be removed or updated to the correct company name, nothing special about that.
Policy violations must be based on the current set of policies as defined in the various AFRINIC policies and RSA, it is best not to define them under a review policy like this one. 
Policies invariably will change at some point in time.

I believe that the policy proposal itself is too specific on too many points:


1)
It only focuses on certain type of resource holders, so it is not "neutral and impartial" which will set a very nasty precedent when it comes to policy making.

2)It gives immunity to policy violators, a "bad" LIR only needs to comply and pass the review to get granted a 24 months immunity, so a "bad" LIR would request to be reviewed themselves, make sure everything is good for the review, and is then free to break any policies they want. As by review policy they are exempted from any further review for a period of 24 months!

3)It is a backdoor to transfers, while transfers are not even yet allowed they are mentioned in the policy, this is again due to the policy not staying neutral in its formulation and trying to be too specific on certain points.


4)Since the policy mentions transfers and it threatens with reclaiming unannounced resources, I will ask what happens if a company transfers a /15 from another RIR to AFRINIC as part of a centralisation of their resources, that LIR gets reviewed. 
AFRINIC decides that the ALLOCATION is not used correctly. 
Only a /17 is used in the African region from within the allocation and the rest is either used out of region (remember the allocation was transferred to the AFRINIC registry) or simply unannounced, would AFRINIC then reclaim the address space that is:
A) currently in use but out of region?
B) unannounced?

Also keep in mind that transferred space, although it should be treated as any other address space, came to its current registered holder after large transfer of money for either the resources themselves (pure IP transfer) or by acquiring 3rd party organisation or networks (merger and acquisition),the latter will inevitably lead to space being used out of region.
Touching such address space such as reclaiming it should only be done in the event of the organisation actually not existing anymore or in gross and clear policy violation, anything else leaves the AFRINIC open for very obvious financial claims from its former holder. Policies must never put the AFRINIC in a dangerous or ambiguous position like that! 


Cheers,
David Hilario


   
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