[rpd] Last Call for "AFPUB-2016-GEN-001-DRAFT-04 - Internet Number Resources Review by AFRINIC"

Mon Jul 24 14:35:05 UTC 2017

Andrew,

Afrinic as Regional Internet Registry mainly  serve  organizations,
companies operating  in this region and their users in this region.
Providers which span multiple regions are supposed to  establish
relationships  with multiple RIRS.
Using part of  the AFRINIC allocated resources outside the region is not
prohibited by default if justified and accepted.
 Hence, policies cannot  explicitely prohibit this. It is left to staff to
apply what it is said  above and follow BCPs.
The RIGHT thing to do is  what this community started last year with the
 review policy proposal. Empower staff and define clear rules on how to
review allocated resources utilization to see how they match the objectives
 of the Regional Internet Registry system and the initial justification of
needs.

2017-07-20 12:41 GMT+00:00 Andrew Alston <Andrew.Alston at liquidtelecom.com>:

> Daniel,
>
>
>
> The problem here is deeper than what you see.
>
>
>
> Firstly, there is nothing in any policy that requires an LIR to have an
> ASN to announce said space.
>
> Secondly – there is nothing in any policy that states that IP addresses
> assigned to entity that is domiciled in the AFRINIC region must be utilized
> within the region – it simply isn’t there
>
> Thirdly – There is nothing in any policy that prohibits charging for IP
> space – and in fact this is extremely common practice in many African ISPs
> (You get X number of IP addresses with the link you purchase, or a dynamic
> IP, if you want more, or you want static IP addresses, you pay extra)
>
> Forth – One of the stated reasons that the LIR pricing from AFRINIC is so
> much higher than the end user pricing is that LIRs have the ability to
> recover the cost from the market – end users don’t.
>
> Fifth – the requirements in the policy says that you have to have
> infrastructure to utilize the space – the problem with this is there is no
> definition of infrastructure – if you are assigning space to other entities
> and are legitimately swipping the space to those entities – the
> infrastructure you yourself require is a system that tracks how the space
> is assigned and a system capable of communicating the swip updates to
> AFRINIC – nothing more.
>
>
>
> Now – let me state categorically – I oppose anyone charging for address
> space assigned by an RIR – if they have bought space on the secondary
> market and paid secondary market prices – then I can understand an attempt
> to regain the cost of said IP space – but beyond that – I have always taken
> the stance that ISP’s charging for space is a bad idea.  I do not however
> oppose the secondary market in the event of space being unavailable from an
> RIR.  I also do not dispute the requirements of needs based justification –
> though in an open secondary market it is my personal opinion that the need
> for this is reduced, since the economics involved will ensure adherence to
> needs base.
>
>
>
> However, what it comes down to is this – if a cloud services provider, or
> a broker, can justify space within the bounds of policy – then the issues
> we face with individuals getting large amounts of space and leasing it out
> to people around the world – are our fault – because we did not modify the
> allocation policies.  We cannot blame those who use the policies as they
> are written and use the loopholes we choose to provide.  We have to take
> responsibility for not tightening the policies – not attempt to create
> audit policies and revocation policies to revoke space that was
> legitimately assigned within the bounds of policy.
>
>
>
> Basically – what I am saying to this community is this – do not blame
> those who use the policies you yourself have passed – if you don’t like the
> policies – change them – and if you cannot get consensus on changing the
> policy then accept that the community does not agree this is a problem –
> that is what bottom up process is about.
>
>
>
> For example – I will oppose any geographic restriction on where space can
> be used until such time as someone comes up with a concrete way to define
> geographic usage of space – something that has been attempted many times
> over the last few years and has failed every time.
>
>
>
> Until such time as someone can concretely demonstrate that someone has
> been allocated space outside of allocation policies though – or is using
> them outside of the rules under which they are allocated – there is no
> cause to do anything – and auditing without evidence or without any
> concrete suspicion of violation of policy is simply not practical.  The
> real issue here is – the policies allow the behavior you describe – like it
> or not – and this community has chosen not to change those policies despite
> this issue being raised consistently over the last 5 or 6 years.
>
>
>
> Andrew
>
>
>
>
>
> *From: *Mwanguhya Daniel Murungi <dmurungi at techsupport.co.tz>
> *Organization: *Techsupport Limited
> *Reply-To: *"dmurungi at techsupport.co.tz" <dmurungi at techsupport.co.tz>
> *Date: *Thursday, 20 July 2017 at 19:12
> *To: *Mike Burns <mike at iptrading.com>
> *Cc: *'rpd List' <rpd at afrinic.net>
> *Subject: *Re: [rpd] Last Call for "AFPUB-2016-GEN-001-DRAFT-04 -
> Internet Number Resources Review by AFRINIC"
>
>
>
> Hello,
>
> I came across this various services offered by Larus cloud services
> amongst them IPv4 sales/trading.
>
> https://www.laruscloudservice.net/ip-delegation-service
>
> Below is an excerpt from the site;
>
> ----------------------
> [IP DELEGATION SERVICE]
> LARUS has a mega pool of IPv4 addresses to provide unmatched IPv4 address
> solutions in the world. IP addresses will be delegated to you directly from
> Larus’s own IP pool. You will use the IP addresses like yours without
> limitation on geography and usage. This is a flexible and speedy service to
> meet your business needs.
> ----------------------
>
> Honestly, I wonder how much IPv4 space from the AFRINIC pool is owned by
> the organization Larus Cloud Services?
>
> I run a couple of whois queries and found the following:
>
> (Organization) : whois -h whois.afrinic.net 'Larus Cloud Service'
> ----------------------
>
> organisation: ORG-LCSL1-AFRINIC
> org-name: Larus cloud service Limited
> org-type: LIR
> country: SC
> address: C/o Abacus (Seychelles) Limited
> address: Mont Fleuri, Mahe
> phone: +359 897641784 <+359%2089%20764%201784>
> phone: +852 2988 8918 <+852%202988%208918>
> admin-c: HL6-AFRINIC
> tech-c: DH15-AFRINIC
> mnt-ref: AFRINIC-HM-MNT
> mnt-ref: LCSL1-MNT
> mnt-by: AFRINIC-HM-MNT
> source: AFRINIC # Filtered
>
> person: David Hilario
> address: Ul. Zaychar 54 floor 3, Apartment 11
> address: Sofia 1309
> address: Bulgaria
> phone: +359 897641784 <+359%2089%20764%201784>
> nic-hdl: DH15-AFRINIC
> mnt-by: mine
> source: AFRINIC # Filtered
>
> person: Heng LU
> address: Ebene
> address: MU
> address: Mahe
> address: Seychelles
> phone: +248 4 610 795 <+248%204%20610%20795>
> nic-hdl: HL6-AFRINIC
> mnt-by: HLU
> source: AFRINIC # Filtered
> ----------------------
>
> Below is a list of resources held by Larus;
>
> whois -h whois.afrinic.net -T aut-num -T inet6num -T inetnum -i og
> 'ORG-LCSL1-AFRINIC'
>
> ----------------------
> inetnum: 196.251.244.0 - 196.251.247.255
> netname: Larus-Cloud-v4
> descr: Larus cloud service Limited
> country: SC
> org: ORG-LCSL1-AFRINIC
> admin-c: HL6-AFRINIC
> tech-c: DH15-AFRINIC
> status: ALLOCATED PA
> mnt-by: AFRINIC-HM-MNT
> mnt-lower: LCSL1-MNT
> source: AFRINIC # Filtered
>
> person: David Hilario
> address: Ul. Zaychar 54 floor 3, Apartment 11
> address: Sofia 1309
> address: Bulgaria
> phone: +359 897641784 <+359%2089%20764%201784>
> nic-hdl: DH15-AFRINIC
> mnt-by: mine
> source: AFRINIC # Filtered
>
> person: Heng LU
> address: Ebene
> address: MU
> address: Mahe
> address: Seychelles
> phone: +248 4 610 795 <+248%204%20610%20795>
> nic-hdl: HL6-AFRINIC
> mnt-by: HLU
> source: AFRINIC # Filtered
>
> ----------------------
>
> One of the sub-allocations/assignment from above Block (196.251.244.0/22)
> is actually assigned to some Saudi Arabia entity as per below whois query.
>
> whois -h whois.afrinic.net -M '196.251.244.0 - 196.251.247.255'
>
> ----------------------
> inetnum: 196.251.244.0 - 196.251.244.255
> netname: SA-ITC-20120518
> descr: Integrated Telecom Co. Ltd
> country: SA
> org: ORG-ITCL1-AFRINIC
> admin-c: IR1052-AFRINIC
> tech-c: IR1052-AFRINIC
> status: ASSIGNED PA
> mnt-by: LCSL1-MNT
> mnt-routes: LCSL1-MNT
> source: AFRINIC # Filtered
>
> ----------------------
>
> Larus Cloud Services has no ASN and IPv6
>
> whois -h whois.afrinic.net -T aut-num -T inet6num -i og
> 'ORG-LCSL1-AFRINIC'
>
> Furthermore, I noticed that the domains laruscloudservice.net and
> cloudinnovation.org have the same owner.
>
> ----------------------
> Domain Name: laruscloudservice.net
> Registrant Name: Heng Lu
> Registrant Organization: Larus Cloud Service Limited.
> Registrant Street: 903 Dannies HSE
> Registrant Street: 20 LUARD RD
> Registrant City: WAN CHAI
> Registrant State/Province: HONG KONG
> Registrant Postal Code: 9741mh
> Registrant Country: HK
> Registrant Phone: +31.641734323 <+31%206%2041734323>
> Registrant Phone Ext:
> Registrant Fax:
> Registrant Fax Ext:
> Registrant Email: h.lu at outsideheaven.com
>
>
> Domain Name: CLOUDINNOVATION.ORG
> Registrant Name: Lu Heng
> Registrant Organization: AnytimeChinese
> Registrant Street: Esdoornlaan 656
> Registrant City: Groningen
> Registrant State/Province:
> Registrant Postal Code: 9741MH
> Registrant Country: NL
> Registrant Phone: +31.641734323 <+31%206%2041734323>
> Registrant Phone Ext:
> Registrant Fax:
> Registrant Fax Ext:
> Registrant Email: er4tmx4khysehimnwr3s at l.o-w-o.info
>
> ----------------------
>
> Cloud innovation
> ================
>
> Cloud innovation and Larus Cloud share the same physical address and
> contacts:
>
> whois -h whois.afrinic.net 'CLOUD INNOVATION'
>
> ----------------------
> organisation: ORG-CIL1-AFRINIC
> org-name: Cloud Innovation Ltd
> org-type: LIR
> country: SC
> address: C/o Abacus (Seychelles) Limited
> address: Mont Fleuri, Mahe
> address: Seychelles
> address: Mahe
> phone: +248 4 610 795 <+248%204%20610%20795>
> phone: +248 4 610 795 <+248%204%20610%20795>
> admin-c: OS9-AFRINIC
> tech-c: OS9-AFRINIC
> mnt-ref: AFRINIC-HM-MNT
> mnt-ref: CIL1-MNT
> mnt-by: AFRINIC-HM-MNT
> source: AFRINIC # Filtered
> person: OutsideHeaven Support
> nic-hdl: OS9-AFRINIC
> address: Ebene
> address: MU
> address: Mahe
> address: Seychelles
> phone: +248 4 610 795 <+248%204%20610%20795>
> source: AFRINIC # Filtered
>
>
> person: OutsideHeaven Support
> nic-hdl: OS9-AFRINIC
> address: Ebene
> address: MU
> address: Mahe
> address: Seychelles
> phone: +248 4 610 795 <+248%204%20610%20795>
> source: AFRINIC # Filtered
>
> ----------------------
>
> In fact, Cloud Innovation Ltd has 2x /11 and 2x /12 IPv4 address space
> allocated to them:
>
> whois -h whois.afrinic.net -r -T aut-num -T inet6num -T inetnum -i og
> 'ORG-CIL1-AFRINIC'
>
> inetnum: 154.192.0.0 - 154.223.255.255
> netname: Cloud-Innovation-v4-II
> descr: Cloud Innovation Ltd
> country: SC
> org: ORG-CIL1-AFRINIC
> admin-c: OS9-AFRINIC
> tech-c: OS9-AFRINIC
> status: ALLOCATED PA
> mnt-by: AFRINIC-HM-MNT
> mnt-lower: CIL1-MNT
> source: AFRINIC # Filtered
>
> inetnum: 154.80.0.0 - 154.95.255.255
> netname: Cloud-Innovation-v4-I
> descr: Cloud Innovation Ltd
> country: SC
> org: ORG-CIL1-AFRINIC
> admin-c: OS9-AFRINIC
> tech-c: OS9-AFRINIC
> status: ALLOCATED PA
> mnt-by: AFRINIC-HM-MNT
> mnt-lower: CIL1-MNT
> mnt-domains: CIL1-MNT
> source: AFRINIC # Filtered
>
>
> inetnum: 156.224.0.0 - 156.255.255.255
> netname: CloudInnovation-infrastructure
> descr: Cloud Innovation Ltd
> country: SC
> org: ORG-CIL1-AFRINIC
> admin-c: OS9-AFRINIC
> tech-c: OS9-AFRINIC
> status: ALLOCATED PA
> mnt-by: AFRINIC-HM-MNT
> mnt-lower: CIL1-MNT
> source: AFRINIC # Filtered
>
> inetnum: 45.192.0.0 - 45.207.255.255
> netname: Cloud-Innovation-v4-I
> descr: Cloud Innovation Ltd
> country: SC
> org: ORG-CIL1-AFRINIC
> admin-c: OS9-AFRINIC
> tech-c: OS9-AFRINIC
> status: ALLOCATED PA
> mnt-by: AFRINIC-HM-MNT
> mnt-lower: CIL1-MNT
> mnt-domains: CIL1-MNT
> source: AFRINIC # Filtered
>
> Cloud Innovation Ltd just like Larus Cloud Services doesn't have any ASN
> and IPv6 as an LIR with so much space.
>
> whois -h whois.afrinic.net -T aut-num -T inet6num -i og 'ORG-CIL1-AFRINIC'
>
> Could all the above explain the vehement opposition of the people listed
> as contacts for both Larus Cloud Service and Cloud innovation [1]?
>
> If so much IPv4 space/resources above was allocated to these LIR's for
> legitimate purposes, it should not be a problem. They will pass review and
> have ability to use the intra RIR transfer too.
>
> Regards,
> Daniel
>
> [1] Heng Lu and David Hilario
>
>
>
> On 2017-07-19 22:55, Mike Burns wrote:
>
> Hi Noah,
>
> There have been over 5,000 policy-compliant global IPv4 sales since
> 2010.
>
> The concept is that the profit motive will incentivize those who hold
> unused addresses make them available to sell them to somebody with a
> need for them. This profit could be an incentive to renumber more
> efficiently to free up blocks, or to provide some compensation for the
> expense of that renumbering.
>
> Without the profit motive, the only other motive is charity.
>
> Charity has not proven to be effective in bringing unused addresses
> back to those who need them, but a market has proven to be quite
> effective.  That said, I know that at least two /8 holders voluntarily
> returned their blocks to ARIN years ago.
>
> A RIPE study revealed that most address sales are of older legacy
> blocks that have not appeared in the routing table for a long time.
>
> This is evidence that the lure of profit has functioned more
> effectively than any prior threat of revocation to move addresses from
> a low- or no-use environment and into the hands of those who need them
> to run operational networks.
>
> In order to foster this market, other registries have removed the
> threat of revocation for utilization from their policies and RSAs in
> order to make it clear to prospective sellers that the registries will
> act as partners to address-holders seeking to sell, and not as judges
> or juries with the power of revocation.
>
> Yes, it is quite a shock that formerly public resources are now
> yielding windfalls for address holders, but the importance of creating
> a market to fulfill the needs of those seeking address has been judged
> to outweigh the queasiness we may feel when witnessing the enrichment
> of address-holders who sell their blocks.
>
> If the role of AFRINIC is to get blocks into the hands of those who
> need them, and the free pool is dry, what is the best way to answer
> that need? One way is to audit, revoke, and recover unutilized space.
> The other way is to harness the profit motive to lift unutilized
> addresses to their “highest and best” use.
>
> ARIN, APNIC, and RIPE debated these two options and chose the market
> route. I think 5,000 transfers is evidence that the correct decision
> was taken.
>
> LACNIC has also chosen to allow a market for IPv4 addresses to
> develop, but unlike the other registries, LACNIC has not removed the
> threat of revocation in its policies and RSA.  A comparison in
> transfer volume between the LACNIC region and the other regions
> provides possible evidence that retaining the revocation threat is
> detrimental to the market, as the volume in LACNIC is very, very low,
> at 10 total transfers to date.
>
> And surely you know that people will be buying and selling IPv4 in
> Africa very soon:
>
> https://www.afrinic.net/en/library/news/2085-afrinic-
> board-ratifies-policy-proposal-ipv4-resources-transfer-within-the-afrinic-
> region
>
> I have facilitated transfers to recipients in 60 countries, and soon
> that will include African countries.  I am proud to have helped get
> address blocks into the hands of the buyers in these countries, and
> there is nothing “so-called” about IP brokerage. It’s a new
> world, Noah, perhaps you should be the one bracing yourself.
>
> Regards,
>
> Mike Burns
>
> IPTrading.com
>
> FROM: Noah [mailto:noah at neo.co.tz]
> SENT: Wednesday, July 19, 2017 3:22 PM
> TO: Bill Woodcock <woody at pch.net>
> CC: rpd List <rpd at afrinic.net>
> SUBJECT: Re: [rpd] Last Call for "AFPUB-2016-GEN-001-DRAFT-04 -
> Internet Number Resources Review by AFRINIC"
>
>
> On Jun 26, 2017, at 8:37 PM, Lu Heng <h.lu at anytimechinese.com>
>
> wrote:
>
> This policy is in direct conflict with transfer policy, if someone
>
> wants to sell their address space, they surely not commit to use it
> with the original purpose, should AFRINIC instead of allowing them
> to transfer the space, but reclaim them and redistribute them for
> "better use"? If that is the case, the transfer policy will have no
> use because of that.
>
>
> Woow
>
> So your worry is that someone will not be in a position to "sell" idle
> IP address space through the transfer policy?
>
> I always thought the fundamental premise was for INR's to be allocated
> for use that can promote internet expansion rather than profit from
> INR's.
>
> On 12 Jul 2017 9:14 a.m., "Bill Woodcock" <woody at pch.net> wrote:
>
>
> I would just like to point out that the AfriNIC community does not
> exist to serve the financial interests of those who wish to sell
> addresses, rather than use them.
>
>
>  + Bill
>
> And whoever in their wildest thoughts think the community shall seat
> back and see them trade IPv4 for any other reason beyond using them to
> build infracture and extend internet related services in AFRICA should
> brace themselves for now.
>
>
> The AfriNIC community is the community of people who need IP
> addresses, in order to route them and give people access to the
> Internet.
>
>
> +1 Bill
>
>
> The AfriNIC policy process exists to serve those who wish to _use_
> IP addresses, not those who wish to profit from them at the expense
> of the community.
>
>
> +1 Bill
>
> Especially those who wish to profit from INR's especially the so
> called IPv4 brokers. There is AFRINIC for goodness sake.
>
> Cheers,
>
> Noah
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-- 
--Abel
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