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

[JORDI PALET MARTINEZ]

Hi Fernando,

I think you missed the previous discussion.

In short. I'm waiting for the staff impact analysis (Ernest any news ?). Once we got that, in addition to resolving any issues discovered by the staff, I will add a "security belt" to the existing text, in the line of:

1.       Each time a transfer is completed, the relevant, non-confidential information will be automatically published in a specific web page, including at least: Date of the transfer, transferred addresses, source organization and RIR, destination organization and RIR. 

2.       The Inter-RIR transfers will only be enabled once AFRINIC enter into Exhaustion Phase 2 (5.4.3.2). 

3.       The Inter-RIR transfers will be automatically suspended in case the number of outgoing IPv4 addresses exceeds the incoming ones by six consecutive months. 

4.       The staff can provisionally suspend any suspicious operation that creates a big unbalance against AFRINIC, until the board takes a decision. 


Furthermore, as part of the discussion, it was clear that Afrinic only allows addresses to be allocated to organizations that provide the services in the region. So even if you open an office in Africa, this is not enough to "get" addresses, unless you prove that you're providing the services there.

Regards,
Jordi
@jordipalet
 
 

El 16/8/19 21:52, "Fernando Frediani" <fhfrediani at gmail.com> escribió:

    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
    
    
    
    
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