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

[Ernest Byaruhanga]

Sylvain,

On 30 Aug 2019, at 12:58, Sylvain BAYA <abscoco at gmail.com> wrote:
> 
> Hi all,
> 
> Please see my comments below (inline)...
> 
> Le 8/29/2019 à 4:56 PM, Ernest Byaruhanga a écrit :
>> Jordi,
>> 
>> 
>>> On Mon, 19 Aug 2019 at 08:49, JORDI PALET MARTINEZ via RPD
>>> 
>>> <rpd at afrinic.net>
>>>  wrote:
>>> 
>>>> 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.
>>>> 
>> 
>> Staff assessment reports for the two transfer policy proposals are available at:
>> 
>>   IPv4 Inter-RIR Legacy Resource Transfers
>>   
>> https://afrinic.net/policy/proposals/2019-v4-001-d1#staff-assessment
>> 
>> 
>>   IPv4 Inter-RIR Resource Transfers (Comprehensive Scope)
>>   
>> https://afrinic.net/policy/proposals/2019-v4-002-d1#staff-assessment
> 
> Dear Ernest,
> After reading your, too much awaited, Impact Analysis report (IAr) i have some questions : 
> 
> • I don't understand why you added the word “currently” in 1.0 a). It seems to render the 
> statement false. {i'm not an English native language though. So excuse my ignorance, where 
> applicable}

That's because the only transfers provided for in CPM 5.7 at this moment are those within the region (Intra-RIR).

> • The RSA (Registration Service Agrement) section 6. (d) (iv), (v), (vi), (vii) states that “[...]the transfer 
> of number resources is strictly prohibited, from except in the event of the Applicant becoming the 
> subject of merger and/or acquisition proceedings or where such transfer is effected in compliance 
> with adopted policies;[...]” ; some of what you wish to prevent, in 2.1 b., seems to be allowed by 
> the RSA...then how to deal with that ?

“..in compliance with adopted policies” is what matters most in your comment above.
We only pointed out the issue (2.1b) in our assessment as a possible avenue for abuse. The community may decide to consider or not to consider this depending on whether they find it a concern or not.

> • In 2.1 a. you seem to suggest that the author also treat the case of ASN transfers, is it not better 
> to encourage any other volunteer to propose such a draft policy proposal ? Don't forget that, 
> these draft policy proposals are just amending the CPM section 5.7. Then, if you add other 
> resources than IPv4, it might sound problematic... :-/

True, but the CPM can be rearranged as appropriate if need be. 

> • I'm not getting the point in 2.2 a. What i mean is that, CPM section 3.4.5 states that after the end 
> of *the last call* on a draft policy proposal has been declared, the Staff has *less than six months* 
> to implement it. Then it automatically starts to serve. Please can you explain why there should be 
> a *special need to specify some conditions on the beginning of this draft policy proposal, if ratified ? 

It had been suggested by some individuals that if Inter-RIR transfers are to be allowed, this should be in exhaustion phase 2. We thought the author could indicate if he has any particular preference as to when Inter-RIR transfers start during the exhaustion phase. Absent of this, it's assumed they take effect immediately after policy ratification of course.

Ernest.