[rpd] Revised Proposal | Resource Transfer Policy (Draft-2)

[Ekaterina Kalugina]

Hello everyone,
I would like to contribute to the present discussion.

First of all, as far as I understood, the proposed resource transfer policy
would allow free transfer of resources with no limitations. I honestly do
not see how this policy “helps bad guys that want to use the resources for
malicious activities.” As I see from the section 5.7.5, in order for the
transfer to take place the receiving RIR has to give its approval. I think
this mechanism is more than enough to prevent potential abuse.

In addition, I would argue it is not up to the RIR to decide who are “bad
guys” and what are “malicious activities.” It is my conviction (please do
correct me if I am wrong), that RIRs are merely registration entities and
therefore cannot pass judgment of whether the receiver of transfer is a
“good” or a “bad” guy. RIRs also should not have any interest for which
purpose the resources are used as long as “technical need” is proven. Also,
according to my knowledge of how the international economy works – it
doesn’t matter if it is “good” or “bad” guys who are requesting the
transfer of resources, long as there is a free flow of resources, and the
commissions are being paid and taxed, it should only bolster the economy in
the region.

In any case, I think we need to abstract ourselves from using moral
categories and focus on the important issues, which are, in my view,
facilitating the economic development of the African region and putting
AFRINIC on equal ground with other RIRs. As far as I can see, this policy
does precisely that. Therefore, I wholeheartedly support it.

Warmest wishes,

Ekaterina Kay Kalugina

On Mon, 14 Sep 2020, 09:51 JORDI PALET MARTINEZ via RPD <rpd at afrinic.net>
wrote:


> If we are asking all the organizations to justify the need and to have

> some wait time for more resources, why we want to have a different view on

> the transfers?

>

>

>

> This only helps bad guys that want to use the resources for malicious

> activities and also makes brokers getting more commissions.

>

>

>

> Regards,

>

> Jordi

>

> @jordipalet

>

>

>

>

>

>

>

> El 14/9/20 5:30, "lucilla fornaro" <lucillafornarosawamoto at gmail.com>

> escribió:

>

>

>

> I agree with your idea that basically corruption may occur (like in any

> other policy and in any other RIR) but there are instruments to avoid it

> and supervise.

>

> I believe that by not supporting organizations that need it due to

> possible dishonesty, we only generate damage and a dangerous precedent.

>

>

>

> Lucilla

>

>

>

> Il giorno lun 14 set 2020 alle ore 11:49 Fernando Frediani <

> fhfrediani at gmail.com> ha scritto:

>

> This type of justification in my view is a justification that only

> benefits brokers and those who are willing to financially speculate from IP

> space instead of using it for what they should be, and goes on the opposite

> direction of other regions even after their respective exhaustion phases.

>

>

>

> Fernando

>

>

>

> On Sun, 13 Sep 2020, 23:38 lucilla fornaro, <

> lucillafornarosawamoto at gmail.com> wrote:

>

> I think that with this proposal AFRINIC would fully be able to support any

> kind of organization in this uncertain period. In fact, due to the pandemic

> situation it is clear that unexpected problems may occur any time. AFRINIC

> should be able to transfer resources even to those that gave up assigned

> resources during the previous 12 months. Only this way it’s possible to

> facilitate the flow of resources from those who have them in excess ( and

> don’t use them) to those who need them and cannot afford to wait 12 months.

>

>

>

> The issue concerning workload is relevant because as the proposal

> supports, transfers won’t need approval from Afrinic. This and the section

> 5.7.5 will help a lot to make the overall working system more efficient.

>

>

>

> I also think that “no upper limit regarding the amount of transfers”

> (section 5.7.3.3) will make a difference when IPv4 will be definitely

> depleted.

>

>

>

> Lucilla

>

>

>

> Il giorno ven 11 set 2020 alle ore 02:53 Fernando Frediani <

> fhfrediani at gmail.com> ha scritto:

>

> Releasing organizations from 12 months period doesn't make any sense and

> goes in the opposite way of good sense. So someone who gave up their just

> assigned resources transferring to someone else. What is the sense of it ?

>

> Smaller organizations can receive resources from AfricNic directly in

> Phase 2, so why would they need to make such transfers ? Also I don't think

> anyone is against allowing transfers Intra and Inter-RIR at the current

> stage. That's not the problem.

>

> I cannot understand what type of "issue" it can cause in terms of workload

> to the RIR and the time required for each request ? What does one thing

> have to do with the other ? If a request fulfill the minimal requirements

> there are no delays or extra workload do process the request.

>

> Regarding the "enrichment of its own financial pocket by Allocation Fees"

> this is still possible for any organizations who requests blocks according

> to Phase 2 so that statement is not correct either.

>

> There is a better well written proposal to allow Inter-RIR transfers under

> discussion which is and I invite others to support it instead which is

> "IPv4 Inter-RIR Resource Transfers (Comprehensive Scope) Draft-4 ". This

> one fulfill completely the need of Inter-RIR transfers for the region.

>

> Regards

> Fernando

>

> On 10/09/2020 11:31, lucilla fornaro wrote:

>

> Hello everyone,

>

>

>

> My name is Lucilla, I graduated in Law and I am currently attending a

> Master Degree in International Business. I would like to give my

> contribution to the discussion.

>

>

>

> For 5.7.3.2: The barrier of 12 months represents an issue for many

> entities that need to face unexpected problems. AFRINIC needs to allow a

> smoother and faster resource transfer to support both smaller

> organizations’ growth, as well as enrich its own financial pocket by the

> Allocation Fees that need to be covered by entities that are not member

> yet.

>

>

>

> And for what concerns other RIR like LACNIC, its policy is proving to

> create some issue. They, as well as the other RIRs, are facing a heavy

> workload because of the dilatation of time required for each request, that

> once approved need to be included into another waiting list due to

> quarantine reasons. These complications cannot be smoothly managed by

> AFRINIC due its shortage of workforce. The section 5.7.3.2 would make the

> overall working system more efficient. Furthermore, LACNIC entered phase 3

> (back in 2017) of the IPv4 Exhaustion, meanwhile AFRINIC is facing a

> different situation.

>

>

>

> I strongly support Section 5.7.3.3: it is positive not to have an upper

> limit regarding the amount of transfer because this will facilitate the

> flow of addresses. IPv4 addresses within the region will soon be depleted,

> transfer policy for IPv4 resources within and outside the region is

> strongly needed.

>

>

>

> Lucilla

>

>

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

>

> *Da:* Fernando Frediani <fhfrediani at gmail.com> <fhfrediani at gmail.com>

> *Inviato:* Thursday, September 10, 2020 1:49:44 PM

> *A:* rpd at afrinic.net <rpd at afrinic.net> <rpd at afrinic.net>

> *Oggetto:* Re: [rpd] Revised Proposal | Resource Transfer Policy (Draft-2)

>

>

>

> I see that point 5.7.3.2 goes in the opposite way of the obvious.

> If an organization gave up of its IP address space because it doesn't have

> usage for it anymore, why would it be allowed to receive more resources

> from AfriNic in short term ?

> Organizations receive IP space upon justification expected to be used to

> serve their customers in a certain time frame ahead. If sudden it realizes

> these addresses are not necessary anymore and transfer them to some other

> organization who really need them why would the source entity be allowed to

> receive even further space ?

> It is not correct to say it drags Afrinic service region backwards in

> comparison to other RIRs. LACNIC and ARIN for example have similar policies

> in regards this topic.

>

> 5.7.3.3. doesn't make sense either to be changed. The current text is

> correct and has a proper reason to be like this, otherwise it opens doors

> to fraud and to organizations to receive IP space form Afrinic and

> immediately to transfer to someone else who cannot receive them anymore

> under the current exhaustion rules.

>

> Therefore I oppose this proposal.

>

> Fernando

>

> On 09/09/2020 11:40, Ibeanusi Elvis wrote:

>

> Hello Everyone,

>

>

>

> My Name is Ibeanusi Elvis. I am a Masters student of Global Law, Politics

> and Peace and Conflict Studies at the Tokyo University of Foreign Studies.

> Highly Interested in Internet Governance and Policy Making specifically

> within the AFRINIC service region.

>

>

>

> In regards to this proposal, I support the Proposed Section 5.7.3.2 as

> source entities are eligible to receive further IPv4 allocations or

> assignments from AFRINIC as long as it complies with current policy

> because a 12 month non-eligibility delay period after transfer

> approval diminishes, hinders and is detrimental to the operational,

> developmental and growth of businesses within the AFRINIC region. Hence,

> dragging the African continent and AFRINIC service region backwards in

> comparison with other RIRs.

>

>

>

> Additionally, Section 5.7.3.2 and Section 5.7.5.3 ensures a swift

> communication between the transferring and receiving RIRs to enhance a

> smooth transfer and receive of allocations and assignments.

>

>

>

> Best regards,

>

> Ibeanusi Elvis .C.

>

>

>

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