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

Andrew Alston Andrew.Alston at
Sat Aug 17 12:52:34 UTC 2019

Hi Fernando, Let me ask you a few questions

* You say AfriNIC still has space – yet because of the soft landing – the size of allocations for which a member can apply are extremely smaller – especially once phase 2 kicks in – so – for those that need more than this – where do you propose they get it in the absence of this policy and the absence of blocks for sale on the continent?
* How does the interest in companies coming from outside to get space have anything to do with the companies on the continent needing to get space from outside? Please explain the correlation
* Please explain how having a transfer policy creates a more fraudulent environment than people who take space off the continent without updating the whois records and outside of the auspicious of the RIR – and how you would ever prove that is actually happening or not.
* You state that those who transfer outside of the system should be sanctioned – under what laws – please cite legal system and case law? Last I checked there was no legal right to determine who can use an integer on the internet
* With regards to “If people run out of ipv4 and cant get more they can use ipv6” – please explain how:
* To do L2VPN circuits in the absence of v4 and the absence of law end hardware to do EVPN (and lack of support for EVPN-VPWS)
* To do traffic engineering when LDPv6 is dead to the point where it’s unusable
* To do L3VPN – which currently in every vendor I’ve tested requires a V4 underlay
* The story about space being taken out of Africa – Please explain why the world would come pillaging Africa – when Africa has such a tiny pool to start with – is it not far easier to go and buy elsewhere in the world where unused blocks are common and available

So – once we get the answers to all of this – then – we can potentially test your hypothesis as stated below – but until then – I can’t see your logic


From: Fernando Frediani <fhfrediani at>
Date: Friday, 16 August 2019 at 22:45
To: "rpd at" <rpd at>
Subject: Re: [rpd] New Policy Proposal Received - "IPv4 Inter-RIR Legacy Resource Transfers (Comprehensive Scope) AFPUB-2019-v4-002-DRAFT01"


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
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

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<> 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

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