[rpd] Legacy holders?

[Noah]

Hi Andrew,

My reasoning follows my personal experience. For some of the ISP's I have
worked with in the past including, those I have guided on the process, the
requirement from AfriNIC member services has always been among other
things, proof that the entity is registered business with physical address
in continent and secondly there has always been a request from member
services team for proof of license from the local regulator for the case of
the ISP's or LIR if you will.

My assumption is that AfriNIC team requests for this document as part of
compliance with the RSA, Bylaws and of-course the written policies. I am
aware that some of the resource members who are not LIR's may not need
scrutiny and can go on getting INR from AfriNIC without a regulatory
license. However, the fact that AfriNIC request for the regulators license
is a process worthy doing because then if we wanted to actually follow up
of possible fraud, then it becomes easier for AfriNIC to contact the local
communications regulator and I suspect this is the reason they request for
this information in the first place.

It terms of the fact that there is zero requirement outside of soft landing
for the use of any RESOURCES on the continent, I agree but however, the
minimum compliance in terms of communications regulatory license are good
enough to somewhat ensure INR are actually used in continent as the said
member will also be paying the local regulator for licensing.

Should this be the case and should this be enforced, I believe so if worse
comes to worse with all the INR hijacking and possible fraud. Dont get me
wrong, those numbers out to be used in continent in line with why AfriNIC
was established in the first place.

Noah

On Mon, Jul 1, 2019 at 7:04 PM Andrew Alston <
Andrew.Alston at liquidtelecom.com> wrote:

> Actually Noah – again – you are wrong.
>
>
>
>    1. There is no CPM requirement for a license – at all
>    2. Section 6.1 is entirely non-specific about what services are in
>    play here – and there are MANY non-licensed services which will fall under
>    that clause
>
>
>
> As an example I can point to several jurisdiction’s where I do not need a
> license to lease a web server and provide hosting services on said server –
> but – if I were to do this – I would a.) be providing services in the
> region and b.) since HTTP is an open standard protocol and can be
> classified as a network service – I would be in compliance – with no need
> for a license
>
>
>
> There are a host of such examples.  Furthermore, that clause says nothing
> about LIR’s – and as such applies equally to everyone – and by your logic
> all PI holders on the continent would not qualify for IP space because of
> that.
>
>
>
> Even in the event that you are hypothetically correct – which I dispute
> let me point out – I can go and get a license – get a transit connection
> from a provider – lease a /24 from them – and provide services on the
> continent with that.  That qualifies for membership of AFRINIC – and again
> – there is zero requirement outside of soft landing for the use of any
> RESOURCES on the continent – the requirement relates to membership.
>
>
>
> So – yet again – you haven’t really thought this through
>
>
>
> Andrew
>
>
>
> *From: *Noah <noah at neo.co.tz>
> *Date: *Monday, 1 July 2019 at 16:09
> *To: *Andrew Alston <Andrew.Alston at liquidtelecom.com>
> *Cc: *"Ronald F. Guilmette" <rfg at tristatelogic.com>, AfriNIC List <
> rpd at afrinic.net>
> *Subject: *Re: [rpd] Legacy holders?
>
>
>
> Andrew
>
>
>
> Routing tables aside :-)
>
>
>
> LIR membership 101 requires that one has a business license and another
> license from a local communications regulatory authority of the country
> where they are requesting space from. Member services team from AfriNIC
> always require this before space is allocated/assigned to an entity.
>
>
>
> The regulators license is required because part of the AfriNIC bylaws
> especially section 6.1 states that usage of INR must be for providing
> services in the African region.This is the case so that its easier for
> Afrinic to comply with provisions of the bylaws that state that INR are to
> used in Africa to support the development of Internet Infrastructure in
> Africa and this is one of the objectives of Afrinic as an RIR whose vision
> and missions are;
>
>
>
> Our Vision
> "Be the leading force in growing the internet for Africa's sustainable
> development"
>
> Our Mission
> "To serve the African Community by providing professional and efficient
> management of Internet number technology usage and development, and
> promoting Internet self-governance."
>
>
>
> Noah
>
>
>
> On Mon, 1 Jul 2019, 09:39 Andrew Alston, <Andrew.Alston at liquidtelecom.com>
> wrote:
>
> Ronald,
>
>
>
> The answer to your question can be found in section 5.5 and 5.6 of the CPM
> – which makes no mention whatsoever of where space must be utilized.  It
> does however state that you must be an AFRINIC member to receive space,
> which is where the requirement that organizations should be domiciled in
> Africa comes from.  This is codified in section 6.1.(i) of the bylaws.
>
>
>
> Beyond that – there is no actual policy ever ratified which precludes the
> use of space off continent outside of soft landing – and that requirement
> can be found can be found in the soft landing policy in section 5.4.6.2
> of the CPM
>
>
>
> During the creation of the soft landing policy – there was actually
> massive debate about that clause – and myself, and others, opposed the
> clause because it’s actually entirely unverifiable – and I’ve never liked
> clauses that impose requirements that cannot be realistically verified.  It
> is virtually impossible to tell where space is actually being utilized
>
>
>
>    1. The BGP tables won’t tell you this – I can have a block of space in
>    Africa that is announced via an African ASN to a non-African player over a
>    layer 2 link
>    2. I can have a block of space in Europe that is announced to an
>    African transit provider in Europe
>    3. Latency tells you nothing – VSAT links are common – and VSAT
>    latency can look very much like long haul latency
>    4. It’s entirely possible for announce an aggregate link in Africa and
>    actually be using all the space out of the continent by sending
>    de-aggregates to selective peers that would be not be publicly visible. In
>    the same way – I could be originating the space from routers in Europe
>    while using IGP de-aggregates to bring it back to the continent and there
>    would be no visibility externally of this.
>
>
>
> That being said – the clause in 5.4.6.2 is also pretty ambiguous – since
> I could easily argue that I could number an entire network in Europe or
> elsewhere without numbering customers – carry transit across that network
> and then back into Africa – and state that the space is solely supporting
> connectivity back to Africa.  In the same way I could number an entire
> branch office off continent and then have that branch office communicating
> back to an African branch – and claim the same thing. Hence, I’m not really
> convinced that 5.4.6.2 is even really realistically enforceable – it is
> all a matter of perspective.
>
>
>
> Just my thoughts
>
>
>
> Andrew
>
>
>
>
>
>
>
> *From:* Ronald F. Guilmette <rfg at tristatelogic.com>
> *Sent:* Monday, 1 July 2019 04:31
> *To:* rpd at afrinic.net
> *Subject:* [rpd] Legacy holders?
>
>
>
> Sorry all. Just two quick rudimentary questions...
>
> 1)
> According to this page:
>
> https://afrinic.net/membership/legacy-resource
>
> "There are currently around 350 legacy resources holders
> registered in the AFRINIC WHOIS database."
>
> Is there a simple list of these organizations anywhere? Or does
> one have go and do tedious data mining on the entire Afrinic
> WHOIS data base in order to just find the names of all of these?
>
> 2)
> Within the WHOIS data base what will be the org-type: value
> for any one of the legacy organizations?
>
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