[rpd] New Policy Proposal Received - "IPv4 Inter-RIR Legacy Resource Transfers (Comprehensive Scope) AFPUB-2019-v4-002-DRAFT01"

[Fernando Frediani]

Hello

I want to position myself against this proposal for the many reasons below.

First I believe this does not bring any benefits to Africa region 
allowing IP space to go out of the region and the same way Africa is not 
in need yet to receive IP space from other regions as AfriNIC still has 
availability for assignment to its members.

Allowing inter-RIR transfers opens a wide door for fraud by 
organizations from other continents establishing a "virtual" or "fake" 
offices in Africa, request some IP space and send them out of the region 
afterwards.
As AfriNIC is the only RIR who still has IP space available for its 
members they should be protected and made sure they are assigned only 
for real usage in the continent.
It is pretty reasonable to think that the major interest will be in 
companies outside Africa to come to the region, get IP space and send it 
out than the contrary as AfriNIC members can get IP space directly from 
the RIR. Why would members need it coming from other regions then ?
Also the 12 months period to request receive more IP space from AfriNIC 
is quiet short in my view and make it worth in order to increase fraud 
for those who wish to send these addresses out of the region.

Even if it's expected AfriNIC's IP space to run out anytime soon I still 
don't believe it is a reason to allow inter-RIR transfers. In LACNIC 
region for example it exhausted IPv4 space for existing members in 2017 
and only very recently after 2 years the inter-RIR transfer has reached 
consensus there, so I think this type of proposal should be re-evaluated 
later on in the future when the scenario changes and when there are real 
benefits for Africa region.

The fact that transfers happen "under the table" I don't consider this 
as a strong argument in favor of this change. Transfers under the table 
are wrong and against the current policies therefore those who may be 
doing it are the wrong ones, not the RIR for not allowing such 
transfers. Any organization who received IP space from AfriNIC must bind 
to the current policies and that includes not to do transfers that are 
not allowed. If they insist on that, sanctions must be applied against 
them, therefore there are mechanisms to properly fix this issue, if it 
exists.

The deployment of IPv6 is not impacted for AfricNIC members for the 
current scenario as IPv4 is still available to be requested by 
organizations for usage by transition mechanisms for example. Even when 
that is not possible anymore there are still alternatives as for 
example: 1) re-use of already hold IP space, 2) establishment of a 
dedicated pool for specific usage with IPv6 transition mechanisms or 3) 
prioritization of new entrants, the last two for example based on the 
/12 reserved for future use as stated by section 5.4.7.1 of the 
AfriNIC's Exhaustion Policy

I also second a comment made by another person in this discussion here: 
"Allowing Inter-RIR transfers open room for resources meant to be used 
in our region being traded fast due to economic reasons beyond the real 
purpose they were meant for which is to help build the African Internet".

Therefore I don't think is good or necessary for Africa region to allow 
inter-RIR transfers and put the RIR under the risk of its address space 
to go out of the region unnecessarily and in an unneeded scenario.

Best regards
Fernando