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

Sylvain BAYA abscoco at
Mon Sep 2 17:46:43 UTC 2019

Hi all,

Please see my comments below (inline)...

Le 9/2/2019 à 9:52 AM, Ernest Byaruhanga a écrit :

> Sylvain,


> On 30 Aug 2019, at 12:58, Sylvain BAYA <abscoco at> wrote:

>> [...]

>> 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).

Dear Ernest,
Thanks for your prompt comment :-)
You are right ! then thanks, i see that i failed to read it correctly :'-(

>> • 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 ?

> “ 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.

...what you say here could have a huge consequence, to my understanding :-/
I mean that, is it the CPM which supersides the RSA ?
...or, on which of the two you (Staff) accord the greatest priority ?

>> • 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.

:-), please could you plan to do it for the other similar cases we

have in this CPM ?

>> • 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.

Thanks for this explanation. IMHO, it would have been better to have
this detail into your IAr :-/


> Ernest.


Sylvain B.
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