[rpd] new version of policy proposal AFPUB-2019-IPv4-002-DRAFT02

[JORDI PALET MARTINEZ]

Hi Owen,

Thanks for the inputs, below in-line with ->.
 

El 7/11/19 18:53, "Owen DeLong" <owen at delong.com> escribió:

    Jordi,
    
    Comments on specific sections:
    
    5.7
    	First, this policy should apply to all organizations with justified needs. There’s no reason
    	to exclude organizations who could get resources from AfriNIC from using the transfer
    	policy if they so choose. Further, the application should be to both recipient organizations
    	(as stated) and source organizations (excluded by present language).
    
    	Recommended alternate language:
    
    		This policy applies to organizations with a justified need for IPv4 resources
    		(recipients) and organizations with IPv4 resources that are no longer needed by
    		the organization (sources).

-> Good point, you're right on that, because it is clear that we are talking about AFRINIC, when enters in phase 2.
    
    5.7.2
    
    	Policy should set source criteria only if the source is within the AfriNIC region. Source
    	criteria for sources outside of AfriNIC should be set by the source RIR. Further, a
    	source organization should not be permanently barred from acquiring additional
    	resources, so I have added a suggestion to allow them to acquire resources via
    	transfer 24 months after acting as a source.
    
    	Recommended alternate language:
    
    	5.7.2 — as is
    
    	5.7.2.1 A source must be validated by the applicable source RIR according to their
    		policies and procedures. A source within the AfriNIC region must be in good
    		standing (all invoices paid) and must be the rightful registrant of the resources
    		to be transferred and there must be no dispute as to the status of said resources.

-> I'm fine with this
    
    	5.7.2.2 Source entities will not be eligible to receive any further IPv4 address allocations
    		or assignments from AfriNIC. Source entities may, if they can show justified
    		need receive resources via transfer after a period of not less than 24 months
    		has elapsed from their last outbound transfer.


-> We have a long discussion about this a about 3 months ago. I'm happy with your proposed text (previously we had 12 months) but I think it was clear that "if you have transferred resources, and need more, use the profit from that transfer to buy more", otherwise, even if 24 months is a long period, is prone to speculation, or even more ... you are using reserves that are better serving people that never transferred resources. Anyway, I will love to hear other voices on this before doing any change here.


    
    	5.7.2.3 An organization which has received resources in the AfriNIC registry within the
    		preceding twelve months will not be approved as a transfer source.

-> Same meaning, shorter and more clarity. I like it. Small modification:

5.7.2.3 An organization which has received IPv4 resources from AFRINIC within preceding 12 months will not be approved as a transfer source.



    
    5.7.3.1 is a bit vaguely worded. Suggest:
    
    	5.7.3.1 Recipient organizations within the AfriNIC service region must be approved
    		by AfriNIC staff using the same policies and procedures as if the request
    		were being satisfied from the AfriNIC free pool.


-> fine for me as well, a bit shorter:

Recipient organizations within the AFRINIC service region must be approved with the same policies and procedures as if the request were being satisfied from the AFRINIC pool.

    
    5.7.3.2 is also a bit convoluted. Suggest:
    
    	5.7.3.2 Recipients in other RIRs must be approved by the staff in that RIR according
    		to that RIR’s policies and procedures.
    
-> again agree and shorter:
Recipients in other RIRs must be approved according to that RIR policies and procedures.


    5.7.3.3 is unnecessary and incorrect in some cases. Many organizations that receive
    resources in the ARIN region are not members, for example. Any intended effect
    in 5.7.3.3 is a subset of the requirements already expressed in 5.7.3.2 and I presume
    that the unintended effects do not need to be preserved. Suggest striking 5.7.3.3
    completely.

-> You're right with the new wording we don't need to say what to do if in AFRINIC or other regions, is already implicit now.
    

    5.7.4 — I think there is a better way to express the actual intent here… Suggest:
    
    	5.7.4 Transfer of ASN with resources
    
    		In the case where the majority of an operating network, including the
    		addresses and the physical infrastructure are being transferred, any
    		applicable ASN(s) may also be transferred at the same time in order
    		to preserve operational integrity and expedience.

-> I don't think we should mention "and the physical infrastructure" as it may not be the case. I suggest a this:

5.7.4 Transfer or ASN with IPv4 Resources

In the case where the majority of the IPv4 resources are being transferred, any relevant ASN(s) may also be transferred at the same time, if the relevant policies are fulfilled.

    
    5.7.5 — This doesn’t belong in the policy text and should be provided instead as
    	guidance to the board and staff for scheduled implementation of the policy.
    
    	Leaving this in the policy text results in a policy manual which contains an
    	ever growing set of anachronisms.

-> The community asked for something explicit in the policy text. If the staff can confirm that we don't need that as part of the policy text and the community accepts that, I'm fine as well. However, if you look at the exhaustion phase, etc., there is timing there. Note that I'm also convinced that it is very difficult to get this proposal, if it reach consensus in December, to be implemented before moving to phase 2, but the staff don't think so (they said it can be implemented in 6 months), and expressed it in the analysis impact (requesting timing as part of the policy, if I got it correctly).
    
    5.7.6	Who determines what information is or is not confidential? Policy should
    		specify exactly what is required to be disclosed and if it wishes to make
    		additional disclosures optional, it should state what those are and that
    		they should be published if disclosed. The list in the existing proposal
    		is a good start on the minimum mandatory information. If we want that
    		as the extent of the policy, suggested rewording:
    
    		5.7.6 Required Disclosures for Transfers
    			Parties shall be required to disclose and AfriNIC shall publish
    			in a specific location, a history of all completed transfers including
    			at least the following information about each transfer:
    
    			+	Date of the Transfer
    			+	Identification/description of the Resources Transferred (e.g. 192.168.48.0/20, AS3223959)
    			+	Source RIR
    			+	Source ORG-ID
    			+	Recipient RIR
    			+	Recipient ORG-ID
    
-> Agree with your confidentiality point. I think a shorter version may be:

5.7.6 Required Disclosure for Transfers

AFRINIC shall publish in a specific location, a history of all completed transfers, including at least: Date of each transfer, identification/description of resources transferred, source RIR and organization, recipient RIR and organization.
   
    Owen
    
    > On Nov 7, 2019, at 07:50 , JORDI PALET MARTINEZ via RPD <rpd at afrinic.net> wrote:
    > 
    > Hi all,
    > 
    > As I've indicated last Monday, during the weekend I've updated the policy proposal AFPUB-2019-IPv4-002-DRAFT02 "IPv4 Inter-RIR Resource Transfers (Comprehensive Scope)" and I'm attaching it here in PDF, so all can read even if not yet published in the website.
    > 
    > This update tries to address:
    > 1) All the issues and inputs from the RPD List and the previous meeting.
    > 2) The staff impact analysis.
    > 
    > At the same time, as it was clear that the community is not interested in a "legacy" only policy proposal (I also expressed myself my concern about that during the meeting, but I wanted to offer "both" choices, just in case), I'm formally withdrawing the proposal AFPUB-2019-IPv4-001-DRAFT01 "IPv4 Inter-RIR Legacy Resource Transfers".
    > 
    > Thanks in advance for reading and contributing!
    > 
    > Regards,
    > Jordi
    > @jordipalet
    > 
    > 
    > 
    > 
    > 
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This electronic message contains information which may be privileged or confidential. The information is intended to be for the exclusive use of the individual(s) named above and further non-explicilty authorized disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited and will be considered a criminal offense. If you are not the intended recipient be aware that any disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited, will be considered a criminal offense, so you must reply to the original sender to inform about this communication and delete it.