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[rpd] Proposal Update received: Internet Number Resources Review by AFRINIC
Jaco Kroon
jaco at uls.co.za
Tue Jun 25 06:58:16 UTC 2019
Hi,
"micro" (total IPv6 space is a single /32, IPv4 is a /22 and /21.
About a day for a single person since we keep records and try to keep
our whois data up to date as well.
So in terms of operational cost, around $1000 USD.
This assumes that AfriNIC will simply require a breakdown of how our IP
space is allocated and not more in-depth analysis of how well (or not)
some of our customers utilize the sub-allocated space, or in some cases,
the wastage as required by some of our upstream service providers.
Kind Regards,
Jaco Kroon
C.E.O.
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On 2019/06/24 17:31, JORDI PALET MARTINEZ via RPD wrote:
>
> I think there is one more cost to be considered here as well.
>
> Each time an ISP gets the audit, it will need to dedicate staff for that.
>
> It is dificult to calculate “how much” that means, as it may depend on
> many factors, such as how big is the ISP, how many resources they
> have, how many customers from different types (business, residential),
> what provisioning system they have, IPAM if any, level of “automation”
> and “inventory” of the network, etc.
>
> May be it is a good exersice for some of you to calculate (rought
> idea), how much staff/resources and how many weeks, this will take to
> you, if the policy it is implemented?
>
> A few examples, could help the community to take a decision.
>
> Regards,
>
> Jordi
>
> @jordipalet
>
> El 24/6/19 17:25, "Timothy Ola Akinfenwa"
> <akin.akinfenwa at uniosun.edu.ng <mailto:akin.akinfenwa at uniosun.edu.ng>>
> escribió:
>
> Hello Andrew,
>
> While I also agree that Staff provide information on the likely
> financial implication for the audit, I don't understand why there
> should be a separate allocation for litigation.
>
> Is it wise for an organisation to budget funds for likely court cases
> when instead they should strive to prevent one in the first place?
>
> For me, I think it is critical to ensure that Staff actions on any
> audit review does not amount to litigation. And this may be captured
> as a suggestion in the policy as well, if necessary.
>
> Best!
>
> Sent from my OnePlus mobile device! </>$aa;
>
> On Mon, 24 Jun 2019, 3:53 PM Andrew Alston,
> <Andrew.Alston at liquidtelecom.com
> <mailto:Andrew.Alston at liquidtelecom.com>> wrote:
>
> I would agree that these numbers would be useful - and must in
> addition include contingent liability allocation for litigation
> that could result due to implementation of this policy
>
> Andrew
>
> Liquid Telecommunications - Group Head Of IP Strategy
>
> ------------------------------------------------------------------------
>
> *From:*Ish Sookun <ish.sookun at lasentinelle.mu
> <mailto:ish.sookun at lasentinelle.mu>>
> *Sent:* Monday, June 24, 2019 5:39:19 PM
> *To:* rpd at afrinic.net <mailto:rpd at afrinic.net>
> *Subject:* Re: [rpd] Proposal Update received: Internet Number
> Resources Review by AFRINIC
>
> Dear PDWG Co-Chairs,
>
> It was expressed during the last meeting that this policy will have
> financial implications on AfriNIC due to costs associated to auditing.
>
> Is it possible to obtain an approximate cost figure (from staff) that
> such audits would entail?
>
> Regards,
>
> Ish Sookun
>
> On 6/8/19 10:24 PM, Dewole Ajao wrote:
> > Dear PDWG members,
> >
> > This is to inform you that authors of the policy proposal named
> "Internet Number Resources Review by AFRINIC" have submitted an
> updated version (Draft version 8) as included below. The URL will
> be shared once published online.
> >
> > Please take some time to go through the proposal contents and
> provide your feedback.
> >
> > Thank you.
> > PDWG Co-Chairs
> >
> >
> > ------------------------------------------------------------
> >
> > ------------------- Begin
> >
> ---------------------------------------------------------------------------------
> >
> > Name : Internet Number Resources Review by AFRINIC (Draft 8)
> > Ref. Name: AFPUB-2016-GEN-001-DRAFT08
> > Status: Under Discussion
> > Date: 7 June 2019
> >
> > Authors:
> > (a) Amelina A. A. Arnaud | <arnaud.amelina at togorer.tg
> <mailto:arnaud.amelina at togorer.tg>
> > <mailto:arnaud.amelina at togorer.tg
> <mailto:arnaud.amelina at togorer.tg>>> | AUF/TogoRER
> > (b) Jean-Baptiste Millogo |<jean.millogo at orange.com
> <mailto:jean.millogo at orange.com>
> > <mailto:jean.millogo at orange.com
> <mailto:jean.millogo at orange.com>>>| Orange Burkina
> > (c) Marcus ADOMEY <madomey at ug.edu.gh
> <mailto:madomey at ug.edu.gh>
> > <mailto:madomey at ug.edu.gh <mailto:madomey at ug.edu.gh>>> |
> University of Ghana
> >
> > 13.0 Summary of the Problem Being Addressed by this Policy Proposal
> >
> > As Internet Number resources are finite, their allocation is
> based on
> > the operational needs of end-users and Internet Services Providers,
> > while avoiding stockpiling in accordance with RFC7020, IPv4
> Allocation
> > Policy CPM 5.5, IPv6 Allocation and assignment policy CPM 6.5
> and Policy
> > for Autonomous System Numbers (ASN) Management in the AFRINIC
> region CPM
> > 7.0.Section 4 of the Registration Service Agreement (RSA)
> provides the
> > framework for investigations of the usage of allocated Internet
> Number
> > resources, defines members’ obligation to cooperate and the
> measures to
> > be taken by AFRINIC in case of failure to comply. The lack of such
> > investigation or regular control can lead to inefficient usage
> of the
> > Internet Number resources, to stockpiling and other type of abuses.
> >
> > 13.0.1 Summary of How this Proposal Addresses the Problem
> >
> > In order to ensure efficient and appropriate use of resources,
> AFRINIC
> > shall conduct regular reviews of resource utilisation held by its
> > members. This would allow recovery of any type of resource,
> where usage
> > is not in compliance with the RSA. Those resources can be
> reallocated
> > for better usage.
> >
> > 13.0.2 Proposal
> >
> > The policy proposal will modify the CPM as follows:
> >
> > Insert a section 13 to the CPM as follows:
> >
> > 13.0 Internet Number Resources Review
> >
> > Regular reviews of resource utilisation are conducted by AFRINIC to
> > ensure efficient and appropriate usage of resources. This allows for
> > recovery of any type of resource where usage is not in
> compliance with
> > the RSA; to allow such resources to be reallocated for better usage.
> >
> > 13.1 The reviews shall be based on compliance with the terms
> outlined in
> > the RSA and Allocation/Assignment Policies.
> >
> > 13.2 The reviews cover all allocated/Assigned resources, but
> priority
> > goes to IPv4 and ASN mappable to two-octet ASN.
> >
> > 13.3 Classes of review: Members to be reviewed shall be selected
> > according to the following classes:
> >
> > 13.3.1 Random
> >
> > The member is chosen by AFRINIC at random between the members
> who has
> > not been reviewed for any other reasons in the preceding 24 months.
> >
> >
> > 13.3.2 Selected
> >
> > Member is selected because of an internal report or due to a
> lack of
> > contact between the AFRINIC and the member.
> >
> > 13.3.3 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 with the same resources
> > portfolio on which a full review has been completed in the
> preceding 24
> > months.
> >
> > AFRINIC staff may, at its sole discretion, after having
> assessed the
> > nature of the evidence found in the community complaint, require
> that
> > such evidence be (i) submitted in the form of a sworn affidavit
> or (ii)
> > declared to be true before a Commissioner of Oath.
> >
> > 13.4 In case of non-compliance and if evidence has been
> established in
> > accordance with:
> >
> > • Breach of AFRINIC policies
> > • Breach of the provisions of the registration service
> agreement or
> > other legal agreements between the organisation holding the
> resource and
> > AFRINIC.
> >
> > AFRNIC shall initiate the resource recovery process on the
> portion of
> > addresses found to be noncompliant.
> >
> > A) AFRINIC shall attempt to contact the organisation and correct any
> > discrepancy towards the RSA. Except in cases of fraudulent resource
> > acquisition or unlawful usage and abuse, the organization shall be
> > given a minimum of six(6) months to effect the return of the
> resources.
> >
> > If the organisation is cooperative and working in good faith to
> > substantially restore compliance or has a valid need for
> additional time
> > to renumber out of the affected blocks, AFRINIC shall negotiate
> a longer
> > term.
> >
> > The acceptance level of compliance and duration of the longer
> term are
> > at AFRINIC staff discretion.
> >
> > B) If the situation cannot be rectified and the member did not
> transfer
> > the resources to meet other AFRINIC-approved needs as per
> adopted policies
> >
> > AFRINIC shall publish the resources to be recovered for a period of
> > three (3) months; during which the organisation may at any time,
> seek
> > compliance or transfer the resources to other members
> >
> > After this period, the resource shall be recovered and
> therefore the
> > records of the previous holder of the recovered resource shall be
> > updated in AFRINIC’s databases.
> >
> > C) Any Internet Number Resources recovered under this policy may be
> > assigned/allocated under existing Allocation and Assignment
> Policies.
> >
> > 13.5 Appeal procedure
> >
> > Reviewed members who are not satisfied have the right to appeal
> against
> > the results on the review within the four weeks following
> communication
> > of the results by AFRINIC. Appeals shall follow an arbitration
> process
> > as provided for in the
> > Code de Procedure Civile (Code of Civil Procedure) of the
> Republic of
> > Mauritius. AFRINIC may, on request from an aggrieved party,
> suggest a
> > pool of arbitrators who shall be knowledgeable volunteers from the
> > community.
> >
> > 13.6 Compliance Report
> >
> > AFRINIC shall publish an annual meaningful report describing review
> > activities, in accordance with all applicable laws and regulations.
> >
> > 13.7 Acknowledgements
> >
> > The authors thank Ms Wafa Dahmani Zaafouri (become Afrinic GC
> Chair), Mr
> > Serge ILUNGA (become Afrinic Board member) and Mr Alain P. Aina for
> > their contributions in the development of this Policy proposal.
> >
> > The authors also thank the community for the discussions and
> contributions.
> >
> > 4.0 Revision History
> >
> > 18 May 2016
> > Version 1.0
> > - First Draft AFPUB-2016-GEN-001-DRAFT01
> > - Posted on RPD list
> >
> > 05 Aug 2016
> > Version 2.0
> > - Second Draft AFPUB-2016-GEN-001-DRAFT02
> > - Change on the policy’s name
> > - Addition of the Acknowledgement section
> > - Rephrasing of section 3.3.3
> >
> > 18 Nov 2016
> > Version 3.0
> > - Third Draft AFPUB-2016-GEN-001-DRAFT03
> > - Update of section 3.3.3 from discussions on mailing list
> > - Update of section 3.7 (Acknowledgements) to thank the
> community for
> > discussions and contributions
> >
> > 11 Apr 2017
> > Version 4.0
> > - Fourth Draft AFPUB-2016-GEN-001-DRAFT04
> > - Update and Rephrasing of section 3.4
> > - Update and Rephrasing of section 3.5
> > - Update and Rephrasing of section 3.6
> >
> > 21 Oct. 2107
> > Version 5.0
> > - Fifth Draft AFPUB-2016-GEN-001-DRAFT05
> > - Adding the paragraph C to 13.3.3. according to the legal counsel
> > proposition
> > - Rephrasing the paragraph 13.5 to comply with staff and legal
> assessment
> > - Rephrasing the paragraph 13.6 to comply with staff assessment and
> > avoid any ambiguity
> > - Changing the co-authors list
> > - Updating the Acknowledgement session
> > - Amending 13.4 (B) to reflect the Transfer policies
> >
> > 06 Apr. 2018
> > Version 6.0
> > - Sixth Draft AFPUB-2016-GEN-001-DRAFT06
> > - Removing categorisation between membership in random class
> section 13.3.1
> >
> > 06 Apr. 2019
> > Version 07
> > - Seventh Draft AFPUB-2016-GEN-001-DRAFT07
> > - Modifying section 13.4 Paragraph A) to clarify the resources
> recovery
> > process: set conditions under which a member could be given
> longer term
> > to effect the return of affected resources.
> >
> > 29 may. 2019
> > Version 08
> > - Eighth Draft AFPUB-2016-GEN-001-DRAFT08
> > - Section 13.3.1 changes to : "..The member is chosen by
> AFRINIC at
> > random between the members who has not been reviewed for any other
> > reasons in the preceding 24 months."
> > - Section 13.4 last paragraph changes to : "AFRINIC shall
> initiate
> > ... on the portion of addresses found to be noncompliant."
> > - Section 13.5 changes to “Reviewed members who are not satisfied
> > have the right to appeal against the results on the review
> within the
> > four weeks following communication of the results by AFRINIC……..”
> > - Typos and grammatical errors fixed.
> >
> -------------------------------------------------------------------------------
> > End
> >
> ---------------------------------------------------------------------------------
> >
> >
> > _______________________________________________
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> >
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