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

Fernando Frediani fhfrediani at
Mon Aug 19 21:52:20 UTC 2019

Hi Owen.
I think we may be starting to divert a bit from the main points of this
policy, though you brought valid points in your argumentation. Let's try
to cover some of them a little more.

Regarding the possibility of ISPs to form another RIR without the
support of ICANN/IANA let's face it, it is not going to happen anytime,
in any way, it's simple as that. Would they be able to convince most or
all Tier 1 networks to accept their announcements out of the filters
they current use based on the current system and whois data ? I hardly
doubt any significant portion of the Internet would support this,
specially out of the current well established internationally RIR system
and the practical effects would be basically null. Even if they are able
to convince a significant portion of the Internet that would not enough
and the effects are equally null.
This reminds me a recently (and yet again) discussion about the
possibility of using 240/4 address space and so far the conclusion is
similar. Can that be used within or without the current RIR system ? Yes
it could, but networks depending on this would suffer at the point these
resources would not be worth using or would be of 'lower quality'.

These supposed impacted ISPs simple don't exist and will never exist
even without a Inter-RIR transfer policy simply because the cost of all
this work to rebel against the current system is so costly that they
would find their ways to keep going with whatever IPv4 space they
currently hold, improve their transition mechanisms, deploy IPv6 as it
happened in other regions. The cost and hassle for this is certainly
much lower than all that trouble generated
That's why discussing in forums like this one are the most effective way
to reach whatever work better for the region for the moment.

I keep my view that at the moment this bring more risks than benefit to
the region, and based on real historic from other parts of the world and
that such a policy can be postponed to a later time, been in 6, 12, 24
month or whatever the community finds more suitable to the region
whenever the time and need really comes.

Best regards

On 19/08/2019 18:19, Owen DeLong wrote:



>> On Aug 19, 2019, at 13:42 , Fernando Frediani <fhfrediani at

>> <mailto:fhfrediani at>> wrote:


>> Hello Owen

>> Thanks for your comments.


>> On 19/08/2019 16:03, Owen DeLong wrote:


>>> <clip>


>>> Sanctioned how? By what power?


>>> RIRs have no legal authority.

>> Oh they do, by different ways.

>> 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 which by the way are completely valid in courts and which give

>> this rights to RIRs to take resources back if any term is violated.

>> 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.


> Sure, but no legal authority stops them (or someone else) from

> deciding to use those same integers in a different way. They can exit

> their RIR contract at any time by allowing the RIR to invalidate that

> registration in the RIR system. If they can find enough ISPs willing

> to accept their use of the addresses in question and their continued

> advertisement of them without the RIR registering them as such, then

> the RIR becomes irrelevant in that process.


>>> Any group of networks that want to create their own registry system

>>> and exchange packets on that basis are welcome to do so.

>> Yes they do, but are you probably know it is not a trivial thing ,

>> specially being recognized but ICANN/IANA and there are strict

>> principles to reach before that

>> (

>> Even if that would ever happen any blocks recovered under the basis

>> mentioned above would never be given to this new registry, so the

>> practical effect of it seems something far from happening.


> They don’t need to be recognized by ICANN/IANA. That’s my point. If

> the RIRs push too hard, then the entire system, ICANN/IANA, RIRs, all

> can get bypassed by the people who run routers.


> The new registry would have full control of to it’s own

> determination. It would be entirely up to the new registry or registry

> system whether they wanted to honor any of the previous IANA/ICANN/RIR

> registrations or not.


> You’re continuing to fail to see that ALL OF THE CURRENT SYSTEM

> operates by consent. Consent of the ISPs, Consent of those running

> internet Exchanges, Consent of the end users (to some extent), etc.


> The power of the RIRs is limited to the consent of the RIR

> participants. If the RIRs create a strong enough reason not to

> consent, they can be bypassed.



>>> Transfers occurring “under the table” are not really under the

>>> table. They are better explained as “transfers occurring outside the

>>> purview of those cooperating with the RIR system”.

>> And that violates the rules agreed by those who form the RIR and

>> support its existence. Either we have rules and policies that

>> everybody agrees to follow to be respected or we don't need any RIR

>> systems.


> But the transfers may or may not involve anyone who “form the RIR and

> support its existence”.


> You are ignoring the fact that not everyone on the internet has signed

> an RSA with an RIR. In fact, the vast majority of internet users have not.


> Everyone who chooses to participate in the RIR system agrees to and

> follows the rules to some extent. Once the RIR system no longer meets

> their needs, there is increasing incentive to bypass that process.


> On a small scale, this likely hampers those choosing to bypass the

> process. However, when the process becomes sufficiently onerous that

> bypass begins to occur on large scale, then it is the RIR system which

> suffers more.


>>> There’s no law that requires anyone to cooperate with the RIR

>>> system. It’s merely convenient and useful for ensuring uniqueness.

>> There are laws that gives full support to contracts signed by between

>> organizations and guidelines that must be followed. We are not

>> talking about something specific or theoretic, but rather something

>> recognized and followed internationally. I don't think any judge

>> would give reason to an organization willing to act unilaterally in

>> this scenario we are discussing.


> Let’s hypothesize…


> An organization was issued block A.0.0.0/8 by the IANA before RIRs

> existed and without any written contract.


> Said organization chooses to sell off 256 separate /16s to 256

> separate organizations without making any effort to record that sale

> in any RIR.


> Because they can show a legitimate history to the acquisition of the

> blocks even though it is outside the RIR system, lots of ISPs accept

> their announcements and they are generally working.


> Under what legal framework or theory are you going to sanction this

> process? How are you going to effectively go after any or all of those

> 257 organizations that never signed a contract with an RIR?


>>> The only power the RIRs have is the number of ISPs who choose to

>>> cooperate with the RIR system. This creates an important balancing

>>> act. If the RIRs act in a manner that is too harmful to the ability

>>> of ISPs (and other address users) to achieve their goals, then the

>>> RIR system will be replaced with something else, or worse, the

>>> internet number management will be come fragmented amongst competing

>>> registry systems and uniqueness will become difficult (at best) to

>>> maintain. OTOH, if the IP using community does not cooperate in

>>> creating useful policies by which the RIR system operates and then

>>> following those policies, it creates a similar set of problems, on

>>> the opposite side of the equation.

>> Useful policies to who ? To just a few cases, to private for-profit

>> companies willing to take profit of these few cases or to majority of

>> the members ?

>> There have been different  views in this discussion, while some

>> believe it is good for the region which is fine, other see there are

>> risks and possible harm to the resources destined to the region and

>> to majority of organizations. Therefore it doesn't seem to be a

>> consensus at the moment and this is not something good at the current

>> system.


> I would imagine useful to the once subscribing to the RIR and

> utilizing address space.


> I never said I thought there was consensus around this policy at this

> time. I said I believed it was for the good of the region as a whole

> and that the risks faced by not implementing it or something similar

> are greater than the risks of implementing it.


> You continue to repeat and point to the (theoretical) risks posed by

> implementing the proposed policy.

> I continue to point out the very real risks that occur if the policy

> is not implemented. You try to convince me that there is some force

> available to prevent those risks. I point out that the force you point

> to is largely unable to address the risks as they exist. This is the

> nature of the deliberative process by which consensus is built or

> fails to be built.


> In the end neither of us knows which way this debate will go. In the

> meantime, both of our arguments are valid and should be considered by

> the community. Eventually, the more convincing set of arguments will

> carry the day.



>>> <clip>

>>> The question isn’t whether the region will stop growing or not… It

>>> will not. The question is whether or not the addresses being used in

>>> the region will continue to be accurately managed by the local

>>> regional registry or whether that registry will become irrelevant

>>> and be bypassed in order to facilitate that process.

>> Do we have in the history any case a scenario like this was raised ?

>> Even with real examples of other RIRs that didn't have a Inter-RIR

>> transfer policy ready when they went to Phase 2 like ? I don't think

>> so. Everything went on and they got a transfer policy at the correct

>> time for their reality. It just doesn't seem the correct time for

>> Africa really. The scenario of chaos if such policy doesn't reach

>> consensus is nonexistent.

>>> <clip>


>>>> Therefore I propose you abandon this proposal for now and

>>>> re-present it in the future when the scenario changes and a policy

>>>> like this is really needed and will bring benefits to the region.


>>> Multiple people have already stated that this policy is already

>>> needed. Despite your continued assertions to the contrary, doesn’t

>>> change the facts on the ground. At this point, I think this policy

>>> is overdue.


>> The same way multiple people stated opposition to this policy for

>> same and different reasons I raised. Before commenting on this thread

>> I have read every single message discussed previously and they are

>> there for who wishes to take their own conclusions.


>> Again I am not against having a Inter-RIR transfer policy at some

>> point in the near future, but at the present in brings more harm than

>> benefits to Africa.



> Any discussion we are having here now is at least six months from

> becoming an implemented policy, so instead of arguing about whether it

> is harmful now, let’s talk about the near future… What is your

> definition of near future? To me, it’s less than 12 months, so if we

> want to have such a policy within 12 months, then the time to fine

> tune it and come to consensus on it is now. If you are looking more

> long-term, then that’s a different story.


> RIR policies are slow-moving. If you wait until the policy is needed,

> you will spend a lot of time with needs being met outside of policy

> before the policy finally gets implemented.


> Maybe you think that’s OK. That’s a perfectly valid perspective, but

> if that’s what you’re saying, then admit it and recognize the reality.


> Otherwise, please consider that “unmet needs” aren’t going to be

> tolerated for very long and businesses will find ways to meet them.

> Preferably within the RIR system through policy changes such as an

> Inter-RIR transfer policy, but otherwise outside of the system.


> Owen


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