[rpd] New Policy Proposal Received - "IPv4 Inter-RIR Legacy Resource Transfers (Comprehensive Scope)

[DANIEL NANGHAKA]

Dear All,

I have been following the IPv4 Inter-RIR legacy Resource Transfer
discussion right from the start. I am in strong disagreement towards this
policy. This policy does not have a benefit for the Africa Region.

Following the presentation at the AFRINIC Meeting in Kampala, it was
highlighted that some of AFRINICs resources were sold on the black market.
The challenge here is that there is no clear record of which resources are
not utilised and the ones that are utilised. The entities that are in
ownership of these resources should provide an evaluation of the respective
assignments - resources that are not being utilised should be brought back
to the AFRINIC Pool for re-assignment.

Secondly, with reference to Inter RIR transfer policy, there is a need to
clearly assess the RIRs that have passed this policy and evaluate where
these resources are going. I am interested in the numbers.

For Africa's case, there is still a need for IPv4 resource and we as a
region we should allow a smooth transition to IPv6 and not force depletion.
Africa's digital economy needs to grow and when some policies are passed
Africa's digital economy will be retarded.


>From an economic perspective, the forces of demand and supply apply. The

high demand for IPv4 resources in other regions shows that the value of
IPv4 remains strong and a necessity. Every Network Engineer knows that IPv4
is needed for IPv6 translation. This IPv4 inter RIR policy when passed,
will lead to a quick depletion in less than 2 months which I think when
passed will be a big risk to the mandate of AFRINIC's formation in managing
of the Africa Region resources. What will be the mandate of AFRINIC after
the IPv4 Policy?

The IPv4 resources were allocated for Africa then why for sure do we want
to transfer what we were given. This is like selling our digital economy.

Based on my opinions above, I strongly do not support this policy.

Daniel K. Nanghaka


On Sat, 17 Aug 2019 at 21:14, <rpd-request at afrinic.net> wrote:


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> Today's Topics:

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>    1. Re: RPD Digest, Vol 155, Issue 9 (Amutuhaire Robert)

>    2. Re: New Policy Proposal Received - "IPv4 Inter-RIR Legacy

>       Resource Transfers (Comprehensive Scope)

>       AFPUB-2019-v4-002-DRAFT01" (Andrew Alston)

>

>

> ----------------------------------------------------------------------

>

> Message: 1

> Date: Sat, 17 Aug 2019 19:50:48 +0300

> From: Amutuhaire Robert <arobert49 at gmail.com>

> To: rpd at afrinic.net

> Subject: Re: [rpd] RPD Digest, Vol 155, Issue 9

> Message-ID:

>         <CAEHKB_wzZtvO+ySU4zCGTZ8KR5_xF8AXZUBS9X=

> 7+paZWZAA_A at mail.gmail.com>

> Content-Type: text/plain; charset="utf-8"

>

> Today's Topics:

>

>    1. Re: New Policy Proposal Received - "IPv4 Inter-RIR Legacy

>       Resource Transfers (Comprehensive Scope)

>       AFPUB-2019-v4-002-DRAFT01" (Fernando Frediani)

>

> Thank you, Mr. Fernando, for the great digest

> I do agree with you.  I also think allowing inter-RIR transfers really does

> open wide a door to fraud and misuse and any other unexpected

> circumstances. It's just so risky

>

> Sincerely,

> Amutuhaire Robert

>

>

>

>

>

> On Sat, Aug 17, 2019 at 3:00 PM <rpd-request at afrinic.net> wrote:

>

> > Send RPD mailing list submissions to

> >         rpd at afrinic.net

> >

> > To subscribe or unsubscribe via the World Wide Web, visit

> >         https://lists.afrinic.net/mailman/listinfo/rpd

> > or, via email, send a message with subject or body 'help' to

> >         rpd-request at afrinic.net

> >

> > You can reach the person managing the list at

> >         rpd-owner at afrinic.net

> >

> > When replying, please edit your Subject line so it is more specific

> > than "Re: Contents of RPD digest..."

> >

> >

> > Today's Topics:

> >

> >    1. Re: New Policy Proposal Received - "IPv4 Inter-RIR Legacy

> >       Resource Transfers (Comprehensive Scope)

> >       AFPUB-2019-v4-002-DRAFT01" (Fernando Frediani)

> >

> >

> > ----------------------------------------------------------------------

> >

> > Message: 1

> > Date: Fri, 16 Aug 2019 16:43:36 -0300

> > From: Fernando Frediani <fhfrediani at gmail.com>

> > To: rpd at afrinic.net

> > Subject: Re: [rpd] New Policy Proposal Received - "IPv4 Inter-RIR

> >         Legacy Resource Transfers (Comprehensive Scope)

> >         AFPUB-2019-v4-002-DRAFT01"

> > Message-ID: <a9363560-d392-21e4-f70f-5552bc12a502 at gmail.com>

> > Content-Type: text/plain; charset=utf-8; format=flowed

> >

> > 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

> >

> >

> >

> >

> >

> >

> > ------------------------------

> >

> > Subject: Digest Footer

> >

> > _______________________________________________

> > RPD mailing list

> > RPD at afrinic.net

> > https://lists.afrinic.net/mailman/listinfo/rpd

> >

> >

> > ------------------------------

> >

> > End of RPD Digest, Vol 155, Issue 9

> > ***********************************

> >

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>

> Message: 2

> Date: Sat, 17 Aug 2019 18:11:28 +0000

> From: Andrew Alston <Andrew.Alston at liquidtelecom.com>

> To: Fernando Frediani <fhfrediani at gmail.com>, "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"

> Message-ID:

>         <

> DBBPR03MB5415BE0A0EDDEB9CAB9628BEEEAE0 at DBBPR03MB5415.eurprd03.prod.outlook.com

> >

>

> Content-Type: text/plain; charset="utf-8"

>

> 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*

>

> Andrew

>

>

> From: Fernando Frediani <fhfrediani at gmail.com>

> Sent: Saturday, 17 August 2019 19:36

> To: rpd at afrinic.net

> Subject: Re: [rpd] New Policy Proposal Received - "IPv4 Inter-RIR Legacy

> Resource Transfers (Comprehensive Scope) AFPUB-2019-v4-002-DRAFT01"

>

>

> 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<

> 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:

>

>      *   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 5.4.7.1<http://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.

>

>

>      *

>

>   *   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><mailto:fhfrediani at gmail.com

> >

> Date: Friday, 16 August 2019 at 22:45

> To: "rpd at afrinic.net"<mailto:rpd at afrinic.net> <rpd at afrinic.net><mailto:

> 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

>

>

>

>

> _______________________________________________

> RPD mailing list

> RPD at afrinic.net<mailto:RPD at afrinic.net>

> https://lists.afrinic.net/mailman/listinfo/rpd<

> https://lists.afrinic.net/mailman/listinfo/rpd>

>

>

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> ************************************

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