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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 18:11:28 UTC 2019

Fernando –

The moment phase 2 kicks in – an ISP will be limited to extremely small blocks – transition mechanisms to IPv6 are *NOT* always a viable alternative – and this was my point – there are a TON of services for which there is NO ipv6 equivalency at the moment – transition mechanisms do NOT facility the use of services that are entirely bound to IPv4 at this point. I can list multiple examples. The solution to this problem is to get feature parity between V4 and V6 – but we’re a long from being there. The solution to this is actually largely found in SR – but, since there is at least one global vendor who has stated categorically that they will not be writing any further control plane code to facility MPLS in relation to V6 – this becomes a problem – unless you implement SRv6 to get the feature parity – and considering that SRv6 in its original form imposes a significantly higher overhead on bandwidth than even the ATM cell tax used to – that’s not viable. So the next option after that would be using SRv6 CRH or SRv6 uSID to remove the overhead – unfortunately that right now is a long way from happening – since its currently stalled in the SPRING WG and there is a deadlock between the approaches and the attempts to mediate and get inter-op so that we can proceed with something we need – hit problems because one of the vendors involved has stated categorically that they have no interest in inter-op on the other standard.

As such – You cannot tell ISP’s to “transition” until there is feature parity on the services they need – you also cannot restrict the ability of an ISP to grow and to function and to provide services. If you do that – rest assured – the ISP in question is going to go and find space from somewhere – and if they cannot transfer it in – because the community refuses to give them a transfer policy – they will either go and establish in another region and bring in the space that way – which takes money off the continent – or they will get the space “under the table”. Rest assured – NOT having a transfer policy – puts service providers that require v4 because of the lack of parity between V4 and V6 at risk – and those ISP’s *WILL* find a way to get space – the only question is – will the methods used to get that space benefit the continent – or result in ISP’s using alternative RIR’s because the RIR that is meant to serve their needs is failing to do so?

I would *LOVE* to get rid of V4 on my network – is it practical? No – not until the feature parity is there – and it simply isn’t – which is one of the reasons I’ve been putting so much work into stuff like SR. As I said at the V6 Ops group in Montreal earlier this year – if you wanna know what hampers IPv6 deployment – which would solve some of these problems – it’s the fact that *THERE IS NO FEATURE PARITY*


From: Fernando Frediani <fhfrediani at>
Sent: Saturday, 17 August 2019 19:36
To: rpd at
Subject: Re: [rpd] New Policy Proposal Received - "IPv4 Inter-RIR Legacy Resource Transfers (Comprehensive Scope) AFPUB-2019-v4-002-DRAFT01"

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.

* 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:

* 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
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<> 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.


* 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.



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><mailto:fhfrediani at>
Date: Friday, 16 August 2019 at 22:45
To: "rpd at"<mailto:rpd at> <rpd at><mailto: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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