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

Jaco Kroon jaco at
Mon Aug 19 09:57:18 UTC 2019


I'm in full agreement with Mark on this.

I also agree with Jordi that we need safeguards in place to avoid abuse
of the policy.

Basically I believe that there was a rule about "if you transfer out
you're not eligible for further space" with a time limit.  Can't recall
the details, but basically my stance is, once you've transferred more
out that you've transferred in (only taking out of region transfers into
account) you're no longer eligible for receiving space from in-region
(by allocation or transfer).

Kind Regards,
Jaco Kroon

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On 2019/08/19 11:49, Mark Elkins wrote:


> Hi Jordi,


> I fully support your transfer proposals..


> I agree that there are some fundamentalists out there but please don't

> let that stop you. Please keep the two proposals alive (the one for

> legacy transfers only - which if passed - will prove you are correct;

> and the other that covers non-legacy address space).


> If we don't have such transfer proposals - then growth will stagnate

> in our region. I don't want to see that. I want to see continued growth!


> On 2019/08/19 11:14, Mike Silber wrote:

>> Hi Jordi


>> While I support the proposal, I think it may be time to give up.


>> This has turned into a debate of “principles" and no facts or logic

>> will be allowed to get in its way.


>> Once we descend to this level - progress is impossible and the

>> fundamentalists have won.


>> Regards


>> Mike


>>> On 19 Aug 2019, at 08:49, JORDI PALET MARTINEZ via RPD

>>> <rpd at <mailto:rpd at>> wrote:


>>> Fernando,


>>> Just look at numbers. Those are not hypothesis, but facts. The

>>> numbers show that the resources are going from the regions that have

>>> “more IPv4” and have deployed “more IPv6” to the other regions.


>>> There is no possible explanation why this will become different if

>>> Afrinic adopts and inter-RIR policy. Do you think ARIN suddently

>>> will stop deploying IPv6 and look for IPv4 addresses form Africa? No

>>> sense!


>>> Regards,


>>> Jordi


>>> @jordipalet






>>> El 17/8/19 18:44, "Fernando Frediani" <fhfrediani at

>>> <mailto:fhfrediani at>> escribió:



>>> 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:



>>>> -          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 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>

>>>> <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"


>>>> 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

>>>> <> 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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> --

> Mark James ELKINS - Posix Systems - (South) Africa

> mje at Tel: +27.128070590 Cell: +27.826010496

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