[rpd] Resources transfer policy Proposal

[Lee Howard]

This is a great approach to responding to comments, thank you.

Lee

On 9/3/19 6:29 PM, ALAIN AINA via RPD wrote:

> Dear community,

>

> We appreciate and thank all those who promptly read, commented  and made suggestions on the proposal.

>

> We do not expect the discussions to turn to non-productive exchanges between co-authors  and contributors.

>

> Allow us to not respond to individual comments, but address the issues raised, as we think this issues-based approach would be more productive

>

>  From this 1st batch of discussions, we noted the following issues and would like to propose the following inputs.

>

>

>

> =============

>

> 1- Elaborate on  "prudent decisions"

>

> prudent = Acting with or showing care and thought for the future.

> When approving transfers (checking conditions on the resources, the source and recipient), evaluating needs justification...,  which involve many parameters,  in the context of evolutions in the co-existence v4/v6, AFRINIC must act cautiously.

> AFRINIC has been doing this as the process on the transfer page can attest. New transfers involving parties outside the membership and the region, other RIRs, requires an emphasis on this. The interests of the region must be preserved as well.

>

> https://afrinic.net/resources/transfers

>

> 2- AFRINIC  doing redistribution which is not its job

>

> AFRINIC is not doing redistribution....the community making decision to allow a specific way of allocating resources...

> The resources are freed and returned to AFRINIC for allocation to a specified recipient  with  AFRINIC approval.

> this is same procedure as for the current intra-RIR policy in use.

>

> 3-  Why not  allow IPv6 transfer

>

> IPv4 and  4-bytes ASN mappable 2-bytes are scarce resources for historical reasons and  it makes sense to allow unused space to be transferred to those who need them.

>

> It is not the case for IPv6. RIR has enough in pool to meet all needs.

> It is also not desirable to start splitting ipv6 blocks  across users.. with the deaggregation  impact.

>

> 4- Why conditions on recipient

>

> Distribution of INRs are needs based and community defines policies which enforce the evaluation of the need before allocations

>

> 5- Detailed  plan on how to use the transferred resources

>

> Nothing new.. all allocations/assignments made by AFRINIC  follow a process of evaluation of the justified needs.

>   Justification of needs for transfer just does not include, max time limit , max allocation/assignment size.

>

> 6- When will this policy enter into force

>

> As soon as implemented by staff... but apply to request for needs which AFRINIC can not meet(  said in the Problem Statement )

> If AFRINIC can meet an INR request from its free pool... priority must be given to  the free pool unless AFRINIC is satisfied by the justification of the requester to do otherwise...

>

> 7-  FTTH, Cloud... etc providers no longer able to make assignments without afrinic approval

>

>

> The sub-allocations and assignments by LIRs are not transfers... these organizations do not need approval from AFRINIC to register assignments in the database and the process for sub-allocations is known..

> This policy does not change these practices

>

> 8- May not meet reciprocity and compatibility of peer RIRs

>

> Each region defines in its policy which Resources are transferable or not and requires that RIRs approved transfers.

> For example, some  have prohibited transfer of certain resources, others did the same  for a number of years.

> This proposal intent is to do the same in solving specific problem this region has.

> It allows :

> 	⁃	legacy from Afrinic region

> 	⁃	legacy transferred into Afrinic pool

> 	⁃	Any resources previously transferred in the region, to be transferred out of region

>

> This constitutes a good basis for a reciprocal transfers between Afrinic and other regions.

>

> This proposal is need based and does not impose any control caps which may have affected  compatibility with others.

>

> Let the debate start, with staff analysis and we shall see how others react to this, but also how things can evolve.

> Policy and decisions in other regions are not immutable too.

>

> 9-  Effect on  resources to be returned to Afrinic as per RSA... etc...

>

> This proposal like the current IPv4 intra-RIR  transfer policy, by allowing transfers of unused resources  from a holder to a specified recipient, do not prevent unused resources to be returned to AFRINIC voluntarily or by application of provisions of the RSA or other policies as applicable.

>

> Resources entitled  to be returned to AFRINIC for some reasons will not be eligible for transfers as per conditions on the source:

>

> “Must be the rightful holder of the resources with no disputes”

>

> In addition to the points above, there were some others about :

>

> - Wait for SL phase 2 and by then must have had enough information to decide on bidirectional inter-RIR transfer

>    

> According to predictions,  phase 2  is due in February 2020.  AFRINIC recently published notice about phase2.

>

> https://ipv4.potaroo.net/

>

> https://afrinic.net/2019-08-19-afrinic-approaches-ipv4-exhaustion-soft-landing-phase-2

>

> - Using  the /12  "reserved for future use”  solely for new comers and justified IPv6 transition

>

> Attempt to do so failed as archives on SL-bis and other related  proposals can show.

>

> Recent SL-update policy approved at last PPM, put the /12 to the free pool to be used in phase2 and revoke the provision of board making decision on it.

>

> Hope this helps

>

> - Co-authors

>

>

>

>> On 31 Aug 2019, at 18:39, Taiwo Oyewande <taiwo.oyewande88 at gmail.com> wrote:

>>

>>

>> A resource transfer policy is required in AFRNIC, but what type of transfer and when should these transfer be implemented are key components to the success of such policy proposals as being discussed.

>>

>> An intra rir transfer policy is required in AFRINIC. The requirements for a transfer in the intra- rir transfer section of this policy proposals are somewhat stiff and can disrupt business flow if implemented. Eg  a transfer of ip between an ISP and a customer will have to wait for a written approval after AFRINIC makes a “prudent decision”.

>>

>> Also, it is in my opinion that to achieve the said goal in this proposals, a two-way inter-rir policy is required. Most RIRs with transfer policy between regions are on the terms that the other region has a two way transfer policy. E.g ARIN and RIPE-NCC.

>>

>> I recommend a two-way inter-rir policy that has safety caps as recommended by some members of the community.

>>

>> Kind regards

>>

>>> On 30 Aug 2019, at 10:57, Sylvain BAYA <abscoco at gmail.com> wrote:

>>>

>>> Hi all,

>>>

>>> Hope you are well.

>>>

>>> Please see my comments below (inline)...

>>>

>>>> Le 8/29/2019 à 12:36 PM, ALAIN AINA via RPD a écrit :

>>>> Dear community

>>>>

>>>> A new policy proposal  named "AFRINIC  resources transfer policy" is submitted for discussions. This proposal obsoletes the current  IPv4  transfer within AFRINIC  service region policy,  defines  rules for  transfers of IPv4  and ASNs  within the region and between AFRINIC service region and other regions.

>>>>

>>>> The policy allows a category of resources to be transferred out of the region, another category of resources to be transferred inside and denies the transfer of certain resources.

>>>>

>>>> We expect this to be a response to a harmonised policy which addresses some of the limitations of the intra-rir policy and proposes a solution for an inter-rir transfer  which minimizes the foreseen risks of uncontrolled outflow of resources.

>>>>

>>>> The co-authors

>>> Dear Alain,

>>> ...i thank you and your co-authors for this interesting and

>>> comprehensive work you have done.

>>>

>>> Really good draft !

>>>

>>>> =====================begin=================

>>>> Draft Policy Name: AFRINIC Number resources transfer policy

>>>> ID: (Assigned by AFRINIC)

>>>> Submission Date: 29 August 2019

>>>> Version: 1.0

>>>> Author(s): (a) Name, (b) Email address, (c) Affiliation, if applicable

>>>>      Gregoire Olaotan Ehoumi, gregoire at ehoumi.net, independent

>>>>      Mukhangou Noah  Maina, noah.maina at seacom.com, SEACOM

>>>>      Komi Elitcha,  kelitcha at djesido.africa, Independent

>>>>      Adeola A. P. Aina, alain.aina at wacren.net, WACREN

>>>>

>>>> Sections of Policy Manual affected

>>>>

>>>> Obsoletes: IPv4 Resources transfer within the AFRINIC Region (Section 5.7 of the CPM)

>>>>

>>>> 1.    Summary of the problem being addressed by this proposal

>>>>

>>>> AFRINIC IPv4 pool is expected to run out soon. Some entities may need IPv4 space to support their IPv6 deployments, especially to support transition mechanisms, which AFRINIC may not meet. The current Intra-RIR policy in force at AFRINIC allows entities to receive unused IPv4 address from other members solely within the AFRINIC region, based on justified needs. Considering the limited IPv4 space initially made available to AFRINIC (AFRINIC managing only 7.23 /8 with a very low ratio of IPv4 addresses per Internet users), there will therefore be a need to allow for unused IPv4 from other regions to move into AFRINIC service region – this without necessarily depleting AFRINIC's slim amount of IPv4 addresses by transferring space out of the region.

>>> ...unless failing under *CPM section 5.4.6.2* ?

>>>

>>>> The current Intra-RIR transfer policy allows all types of IPv4 allocations/assignments to be transferred, including IPv4 from special purpose blocks (reserved blocks for IXPs and DNS root ops, Last /8, etc.)

>>>>

>>>> The current intra-RIR transfer policy does not cover ASNs while there are cases where transfers of ASNs among AFRINIC members is desirable.

>>> ...real problem, but need a different draft policy proposal to address

>>> it, unless you plan to have

>>> the content of this draft policy proposal (if ratified at end) in a

>>> specific new section for all Internet

>>> Resource Transfers.

>>>

>>> For the latter i will suggest you to also consider IPv6 address space

>>> into your Resources definition.

>>>

>>>> 2.    Summary of how this proposal addresses the problem

>>>>

>>>> This new policy defines a set of rules to allow transfer of IPv4 addresses and ASNs within AFRINIC service region and between AFRINIC service region and other regions

>>> Please explain me why not also IPv6 addresses ?

>>>

>>>> by specifying what categories of resources are eligible for transfer, the location of parties (sources and recipients) and the conditions to be met.

>>>> The policy segregates the resources in different categories and defines which transfer rules applied to each category.

>>>>

>>>> Only Legacy resources and resources previously transferred from other regions will be transferable out of the AFRINIC service region.

>>>>

>>>> It also states the following:

>>>>

>>>> Number resources are non-transferable and are not assignable to any other organisation unless AFRINIC has expressly and in writing approved a request for transfer. AFRINIC is tasked with making prudent decisions on whether to approve the transfer of number resources.

>>> ...i have not seen this in section 3 below. Is it not mandatory ?

>>>

>>> Or is it just about what we are reading in RSA section 6. (d) (vi) ?

>>>

>>> Also, what do you mean by “prudent decisions” ? Could you clarify please.

>>>

>>>> IPv4 addresses and ASNs can be transferred only in accordance with the following policy. AFRINIC does not recognise transfers outside of this policy and its predecessor and requires organisations holding such resources to return them to the appropriate registries.

>>> ...almost the same comment as my preceeding :-/

>>> Please can you elaborate on the expected impact of this ?

>>>

>>>> The goal of this transfer policy is to help distribute resources from those who no longer need them to organisations that need the resources, but cannot obtain them from the AFRINIC  free pools.

>>> Noted !

>>>

>>>> AFRINIC recognizes the following types of transfers:

>>>> - merger, acquisition or takeover,

>>>> - between AFRINIC members,

>>>> - between an AFRINIC member and a member of another RIR,

>>>> - between a Legacy holder and an AFRINIC member,

>>>> - between a Legacy holder and a member of another RIR.

>>> ...have not seen in section 3. Why please ?

>>>

>>>> AFRINIC will process and record Inter-RIR resource transfers only when the counterpart RIR has an Inter-RIR transfer policy that permits the transfer of IPv4 address space and ASNs between its own region and AFRINIC.

>>>>

>>>>

>>>> 3.    Proposal

>>>>

>>>> 3.1 Definitions

>>>>

>>>> 3.1.1 “Resource” refers to IPv4 Address space or Autonomous System Numbers.

>>>> “AFRINIC pool” means AFRINIC managed pool of IPv4 and ASNs, obtained from IANA (allocated and recovered) or through the ERX (Early registration transfers).

>>>>

>>>> 3.1.2 “Special-Purpose pool” means the pool of resources currently reserved for Critical Internet Infrastructures (section 5.6.4 of CPM) and last /8 (section 5.4.1 of CPM).

>>>>

>>>> 3.1.3 “Legacy resources” refer to resources allocated prior to the RIR system and tagged as Legacy by AFRINIC.

>>>>

>>>> 3.1.4 “Others” means resources transferred from other regions through Inter-RIR transfer.

>>>>

>>>> 3.1.5 “Inter-RIR transfer” means the transfer of resources from an AFRINIC member to a member of another RIR or vice-versa.

>>>>

>>>>

>>>> 3.2 Marking of the resources

>>>>

>>>> AFRINIC pool == Regional

>>>> Special-Purpose pool == Reserved

>>>> Legacy == Legacy

>>>> Others == Global

>>>>

>>>> 3.3 Rules and procedures for selecting resources eligible for transfers

>>>>

>>>> 3.3.1 If source and recipient are AFRINIC members, then allow “Regional”, “Global” or “Legacy” for transfer and mark transferred “Legacy” as “Global”

>>>>

>>>> 3.3.2 If source is Legacy holder and recipient is AFRINIC member, then allow “Legacy” for transfer and mark transferred resources as ”Global”

>>>>

>>>> 3.3.3 If source is Legacy holder and recipient is in another region, then allow “Legacy” for transfer

>>>>

>>>> 3.3.4 If source is AFRINIC member and recipient is in another region, then allow “Global” for transfer

>>>>

>>>> 3.3.5 If source is from another region and recipient is AFRINIC member, then allow “Any”, and then mark the transferred resources as “Global”

>>>>

>>>> 3.3.6 Irrespective of the source and recipient, if resource to be transferred is “Reserved” then deny transfer.

>>>>

>>>> 3.4 Conditions on resources to be transferred

>>>>

>>>> - The size of the IPv4 address should be a minimum of /24.

>>>> - The resource must qualify for type of transfer requested.

>>> ...you might consider adding this condition :

>>> • The resource must not fall under a situation on which it should be

>>> returned to AFRINIC as

>>> clearly stated by the RSA section 6. (d) (vii)

>>>

>>> Please tell me, might it be productive to also add the following

>>> condition here ? or not ? Why ?

>>> • MUST show past usage rate if applicable.

>>>

>>>> - The resource will be covered by AFRINIC policies after transfer into the region.

>>>>

>>>> 3.5 Conditions on the source

>>>>

>>>> - Must be right holder of the resources to be transferred with no disputes.

>>>> - If the source is from other regions, conditions on the source are defined in the counterpart RIRs transfer policy.

>>> ...question : how this draft policy proposal is dealing with a source

>>> organisation which should normally return (see RSA section 6. (d) (vii))

>>> such resources to AFRINIC ?

>>>

>>>> 3.6 Conditions on the recipient

>>>>

>>>> - Will be subject to current AFRINIC policies.

>>>> - Must sign RSA.

>>> Why not this alternative : MUST be an AFRINIC resource member in good

>>> standing...

>>>

>>> Thanks.

>>>

>>>> - Recipient that does not have prior resources must:

>>>> ++ demonstrate a detailed plan for the use of the transferred resources

>>>> (in the case of ASN, recipient must meet the criteria for assignment of ASN).

>>>> - Recipient with prior resources must:

>>>> ++ demonstrate a detailed plan for the use of the transferred resources

>>>> (in the case of ASN, recipient must meet the criteria for assignment of ASN).

>>>> ++ Show past usage rate.

>>>> ++ Provide evidence of compliance with AFRINIC policies with respect to past allocations/assignments.

>>>> - If the recipient is in another region, the conditions on the recipient are defined in the counterpart’s RIR transfer policy.

>>>>

>>>> 4.    Revision History

>>>>

>>>> v1 submitted on 29/08/2019 for discussions

>>>>

>>>> 5.    References

>>>>

>>>> https://www.nro.net/wp-content/uploads/NRO-Statistics-2019Q2.pdf

>>>> https://www.potaroo.net/tools/ipv4/

>>>> http://bgp.potaroo.net/iso3166/v4cc.html

>>>> http://resources.potaroo.net/iso3166/ascc.html

>>>> ftp://ftp.afrinic.net/stats/afrinic/transfers/

>>>>

>>>> ===================end=======================

>>> Shalom,

>>> --sb.

>>>

>>>> [...]

>>> -- 

>>>

>>> Regards,

>>> Sylvain B.

>>> <http://www.chretiennement.org>

>>> __

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