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

[Fernando Frediani]

Hi
This is not about a "hypothesis" but rather a quiet obvious and logic 
thing to face. If Africa is the only region that still has space left 
for its members and the rest of the world is seeking for more IP space 
at lower cost it makes total sense for someone to think in trying to get 
IP space form this region and send them out to where is interesting to 
them if such proposal ever reach consensus. Luckily I don't think it 
will be the case given the number of oppositions raised and good points 
put against it.
I think maybe you misunderstood some of what has been said and discussed 
about this topic but I will try to answer some of the points raised.

On 17/08/2019 09:52, Andrew Alston wrote:
>
> 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?
>
This is not true. In the current phase an African member who needs IP 
space can just request, justify and will get the addresses needed. Just 
when it enters phase 2 it will still be possible to get a smaller block 
and at that point ISPs should have done their homework to prioritize the 
addresses they already hold to transition mechanisms rather than the way 
they were used to use in the past. That is probably the reason this is 
called soft landing. Nobody can be get by surprise.
The most important is that as it stands now African members can get IP 
space normally, they don't need to go to the market to get extra space 
and it is a reason that reinforces that this proposal brings zero 
benefit to the region.
And the fact local members can still get the space they request, this 
proposal should not pass, otherwise it will be a even higher risk of 
fraud from external organizations at the current Phase of IPv4 Exhaustion.
(Source: https://www.afrinic.net/cpm-1-0#s5_4)

>   * 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
>
I believe it is pretty much explained above, but lets go a bit more into 
it. Companies from other regions may find cheaper to open a "fake" or 
"virtual" company in Africa region to get addresses from here and 
afterwards request a transfer to another RIR where the address will 
really be used by them. The cost to buy a /24 or a /22 in the market 
makes the economics pretty worth for fraudsters to do all necessary and 
bureaucratic work to open up and fake company in Africa in the attempt 
to get these addresses.
>
>   * 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
>
I think maybe you misunderstand either what I said or how the RIR system 
works. When any organization becomes a RIR member and receives a block, 
it is obliged to use it according to the current rules, policies and 
behave according to the bylaws and the contract they signed and agreed. 
There are cases where violations on the policy or how the organization 
handle the IP space can get these resources revoked from the 
organization. This works like that on any RIR, not just in AfriNIC.
Therefore if the current policies don't allow transfers "under the 
table" (quiet obvious) and if such wrong attitude and violation of the 
policy proved the resource holder doesn't have usage for that IP space 
it can be revoked by the RIR. Simple as that !
>
>   * With regards to “If people run out of ipv4 and cant get more they
>     can use ipv6” – please explain how:
>       o 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)
>       o To do traffic engineering when LDPv6 is dead to the point
>         where it’s unusable
>       o To do L3VPN – which currently in every vendor I’ve tested
>         requires a V4 underlay
>
I am not sure what you are trying to say with that.
When an organization cannot get **any more address** (therefore only 
after phase 2 is finished- a while from now) it means it still has 
address to use or re-used for different and more efficient proposed as 
transition mechanisms and until that happens the dependency on IPv4 will 
be lower than it is now a days. Still on such scenarios there are still 
alternatives as for example the mentioned in the previous message to 
create a new policy to assign that last /12 revered under section 
5.4.7.1 for new entrants and for IPv6 transition mechanisms as it exists 
in other RIRs.
At that point maybe will be a better time to discuss a Inter-RIR 
transfer policy again with much less risk that addresses will be looted 
from the region.
>
>      o
>
>
>   * 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
>
Explained above about the economics that make it worth for fraudster to 
come to the region, establish a company to get addresses and then 
request the transfer out of the region. This is not just a point of 
view, but pretty much an easy mathematics question.

Said that, I am unable to see **any benefit** such proposal bring to 
African region at the current scenario. Instead it only bring risks (in 
the current Phase 1 even higher risks) and maybe the only beneficiaries 
to this policy will be the IP transfer companies and as far as I know 
it's not the mission of any RIR to create policies to benefit such entities.

Fernando

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