[rpd] Resources transfer policy Proposal

[Anthony Ubah]

Hello Paschal,


You have buttressed my earlier submission in this fora.

With the region poised to move in to the next phase of resource allocation,
there will be a growing need for IPv4 space to support IPv6 deployments and
transition mechanisms.
Thus, the growing worries that AFRINIC may struggle meet up to these
demands. This has been a source for worry for sceptics, conservatives and
the business community at large.


Although the existing Intra-RIR policy caters for transfer of unused IPv4
address from members within the AFRINIC region. The community has to keep
in mind, the very low ratio of IPv4 addresses per Internet users in the
region. Africa's need to allow for unused IPv4 from other regions to move
into AFRINIC service region is critical.
For ease of doing business in the region and growth potential, it is
imperative to put forward a full  2-way resource transfer policy and
guidelines.

I have previously argued about the new newly proposed and existing
Intra-RIR transfer policies, that;

1. Redistribution of resources is simply overstretches of the scope of
AfRINIC. Such additional responsibilities will create clogs in a system
with should be an otherwise smooth and fluid system.

2. On the conditions for recipient of “resources”, I feel the conditions
proposed will generate an adverse result and will fail in its main
objective being, to encouraging massive resource inflow into the region.

3. Ease of doing business in the region; The proposed scrutiny, analysis
and justification of parties and resources will create bureaucracy and
cause bottleneck for old and new business operations needing resource
transfer.

My deduction from the new policy proposal is, that new businesses with no
existing regional resources might have difficulty or be forbidden from
acquiring and/or transferring resource into the region, and I this is
counterproductive.

Afrinic and the community needs to properly manage the resources at the
disposal of the region, and prevent syphoning of resources in deals done
under the table. Nevertheless, these objectives should not hamper growth
and development of the region. Efficiency, and excellent business and
service delivery within the region is key to growth.
In conclusion I propose nothing short of a full duplex Inter-RIR resource
transfer policy with less ambiguous, seamless processes and a lubricated
path which can glide the Region forward to keep up with Global pace.

Anthony

On Mon, Sep 23, 2019, 07:20 <rpd-request at afrinic.net> wrote:


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>    1. Re: Resources transfer policy Proposal (Paschal Ochang)

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> ----------------------------------------------------------------------

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> Message: 1

> Date: Mon, 23 Sep 2019 07:19:26 +0100

> From: Paschal Ochang <pascosoft at gmail.com>

> To: "rpd >> AfriNIC Resource Policy" <rpd at afrinic.net>

> Subject: Re: [rpd] Resources transfer policy Proposal

> Message-ID:

>         <CAMU0wT7fPpgp+M12BNXuXyZ78K9JAO-zKT6-J=

> 6ijObMkaqdZA at mail.gmail.com>

> Content-Type: text/plain; charset="utf-8"

>

> There already exist guidelines in resource assignment so the statement that

> Afrinic has to analyse and justify any transfer is ambiguous at most and

> might create a bottleneck for business operations when there is a large

> volume of requests for resources  requesting speedy approval by Afrinic.

> Furthermore what is the turnaround time for this approval and justification

> by Afrinic? Please our need for preventing or curbing shady deals should

> not introduce complexity and reduce efficiency in the operations of

> resource holders and legitimate resource request. A full bidirectional way

> transfer is also the best desirable outcome if at all we need a transfer

> policy which I think we do.

>

> On Thursday, September 5, 2019, Taiwo Oyewande <taiwo.oyewande88 at gmail.com

> >

> wrote:

>

> >

> > Dear all,

> >

> > I appreciate the well coordinated reply by the co-authors.

> >

> > Based on my previous comment, I am still of the opinion that transfer of

> > resources within the region should be less stiff. Afrinic is an Internet

> > registry for Africa centred at distributing Internet number resources and

> > having an updated ledger of its distributed resources. With this, Number

> > resources should be able to move freely within the region as long as a

> > valid need is shown and a written notification is sent to AFRINIC to

> update

> > her books for proper and up to date record keeping. The decision making

> > process in this proposal is time consuming and can affect business

> > operation.

> >

> > Kind regards

> > Taiwo

> >

> > > On 4 Sep 2019, at 17:11, Fernando Frediani <fhfrediani at gmail.com>

> wrote:

> > >

> > > Hi Lee

> > >

> > >> On 04/09/2019 12:00, Lee Howard wrote:

> > >>

> > >> <clip>

> > >>

> > >>> Newcomers are the most important to be privilege in my view in the

> > future for a question of fairness so make sure they are treated the same

> > way all others were in the past and give them a chance to exist in the

> > Internet without any artificial difficulties.

> > >> I mostly agree with you, but I think this can be handled as well by

> > reserving addresses for IPv6 transition mechanisms.  A newcomer who is

> > building an IPv4 network is saying they only want to grow for one year.

> > >

> > > The way I see is the a newcomer wouldn't want (or be able) to build a

> > IPv4 network when he is receiving only a /22, but to use most of these

> 1024

> > addresses for transition mechanisms as he wouldn't have a escape anyway.

> > The difference from a dedicated policy for IPv6 transition mechanisms is

> > that it gives a little more flexibility to that organization to grow and

> > stabilize itself. Then if beyond that they still need more address they

> can

> > go to market.

> > > A dedicated IPv6 transition policy is more toward those who already

> have

> > some allocation from the RIR and it works in even smaller portions of

> > addresses as it is in ARIN for example.

> > >

> > > Fernando

> > >

> > >>

> > >> Lee

> > >>

> > >>>

> > >>> Regards

> > >>> Fernando

> > >>>

> > >>>>

> > >>>> 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 ? 12:36 PM, ALAIN AINA via RPD a ?crit :

> > >>>>>>> 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>

> > >>>>>> __

> > >>>>>> Website : <https://www.cmnog.cm>

> > >>>>>> Wiki : <https://www.cmnog.cm/dokuwiki>

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