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

[Gaby Giner]

Hello everyone,

I will take this opportunity to make my stance regarding this proposal. As
the idea of mutual transfer between RIRs of scarce resources is beneficial
for both parties, I strongly support it.

As I have said, the premise of the proposal is simple, and as Cathie said -
functional. Given the point that AFRINIC is the only one without an
Inter-RIR transfer policy, it would be prudent for AFRINIC to have one in
order to somewhat level the playing field (so to speak). Even if we
cost-benefit analyze this, AFRINIC gains more in having this policy than
continuing in the future without one.

Cheers, Gaby.


On Thu, Sep 17, 2020 at 3:03 PM lucilla fornaro <
lucillafornarosawamoto at gmail.com> wrote:


> Hello Cathy,

>

>

> You made a good observation. Afrinic only has 3% of world space, which

> means that there is not a real reason to worry. This transfer policy will

> finally put Afrinic in the same position as the other RIRs.

>

> 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. And

> this will make the difference once the IPv4 resources will be depleted.

>

>

> Most importantly, it is not up to Afrinic to offer a fraud prevention

> service, and this policy does not in any way encourage malicious or

> fraudulent activities.

>

>

>

> best wishes,

>

>

> Lucilla

>

> Il giorno gio 17 set 2020 alle ore 04:29 Cathie Jay <

> cathie.kay89 at gmail.com> ha scritto:

>

>> Dear all,

>>

>> I fully support this policy which would allow a mutual transfer of

>> resources between two or several African regions. It is a completely

>> functional policy, which is primarily need-based. AFRINIC is the only

>> RIR without a transfer policy and has only 3% of the world space.

>> Therefore AFRINIC is gaining a lot more by adopting this policy. I

>> would also add, after following the several discussions on the list,

>> that this policy does not address internet fraud in any wat. What is

>> enhanced here is the free flow of transfers.

>>

>> All best wishes,

>>

>> Cathie

>>

>>

>> On Tue, Sep 15, 2020 at 7:03 PM dc at darwincosta.com <dc at darwincosta.com>

>> wrote:

>> >

>> >

>> > On 15 Sep 2020, at 17:53, Daniel Yakmut via RPD <rpd at afrinic.net>

>> wrote:

>> >

>> > 

>> > The highlighted hurdles can hold up the policy reaching a consensus on

>> time to be relevant.

>> >

>> > Hence I see the simplicity of the intra RIR transfer as something that

>> we can agree on and put to use as soon as possible. The free flow market

>> makes it attractive and self controlling.

>> >

>> > Self controlling? What do you mean by that?

>> >

>> > I rather stick with Fernando’s last quote:

>> >

>> > This talk about "free flow market" is something that only benefits

>> those willing to misuse IP space and profit from it instead of using it for

>> its main propose which is ensure Internet can continuing developing in the

>> region.

>> >

>> >

>> > Simply,

>> > Daniel

>> >

>> >

>> > Darwin-.

>> >

>> >

>> > On Sep 14, 2020 8:21 PM, "Mike Burns" <mike at iptrading.com> wrote:

>> >>

>> >> Hello,

>> >>

>> >>

>> >>

>> >> Apologies for yet more input from outside the region.

>> >>

>> >>

>> >>

>> >> We don’t want registries deciding good and evil uses for addresses, we

>> want them accurately maintaining a list of unique numbers and their

>> registrants, per the ancient RFC2050.

>> >>

>> >>

>> >>

>> >> The future is just about here and will arrive when AFRINIC reaches

>> full exhaust. It’s time for the registries to recognize that conservation,

>> one of the original purposes of the RIRs, is now performed automatically by

>> the market. People don’t waste valuable resources as a rule.

>> >>

>> >>

>> >>

>> >> Now is the time for the RIRs to concentrate on their only other

>> purpose besides conservation, and that is accurate registration.  To meet

>> the absolute requirement of unique registration, it’s important that RIRs

>> do not implement policies that run counter to normal business activities

>> like transfers, lest those policies engender things like unregistered

>> leases or sales resulting in inaccurate registrations.

>> >>

>> >>

>> >>

>> >> To bring this discussion back to the point, what is the likelihood

>> that an AFRINIC member will have the time to justify and acquire addresses

>> from AFRINIC, sell them to another AFRINIC member while the free pool still

>> exists, and go back to the free pool for another allocation?  Remember

>> there is still not inter-regional policy, so the only buyer would be

>> another AFRINIC member who would have to justify his need in order to

>> purchase addresses, and he could simply utilize that same justification to

>> get the addresses directly from AFRINIC.

>> >>

>> >>

>> >>

>> >> And this policy would still have to reach consensus and be

>> implemented, making it that much farther away in time, as the remaining

>> pool shrinks.

>> >>

>> >> I think it’s a moot point and resell limits as a rule are an

>> impediment to a free-flowing market. And I say that as the original author

>> of the 12 month time limit in ARIN policy.

>> >>

>> >>

>> >>

>> >> Regards,

>> >> Mike Burns

>> >>

>> >>

>> >>

>> >>

>> >>

>> >>

>> >>

>> >>

>> >>

>> >>

>> >>

>> >>

>> >>

>> >>

>> >>

>> >>

>> >>

>> >> From: Fernando Frediani <fhfrediani at gmail.com>

>> >> Sent: Monday, September 14, 2020 2:46 PM

>> >> To: rpd at afrinic.net

>> >> Subject: Re: [rpd] Revised Proposal | Resource Transfer Policy

>> (Draft-2)

>> >>

>> >>

>> >>

>> >> On 14/09/2020 15:21, Ekaterina Kalugina wrote:

>> >>

>> >> <clip>

>> >>

>> >>

>> >>

>> >> 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.

>> >>

>> >> It is up to the RIR to oversee how resources are used and if they are

>> not used for the proposes they were originally justified they should be

>> recovered and re-assigned to other organizations who commit to use them how

>> they should be: to make the Internet work, evolve and to get more people

>> connected to it.

>> >> If organizations are just holding IP space in order to make them worth

>> more in order to sell them later and profit from it then they are not using

>> this scarce resource as originally justified and they better be

>> re-distributed to those who really need them.We are talking about a scarce

>> shared owned resource and not a private properly which can be produced any

>> anytime.

>> >>

>> >> If no justification would be necessary then it would be unfair with

>> those who need the IP space to make the internet to work.

>> >> Overall it is up to the RIR to determine the rules and conditions

>> these resources be justified which is done on each regional policy forum.

>> Furthermore each organization signs an contract with the RIR agreeing to

>> bind to these rules in order to keep these resources.

>> >>

>> >>

>> >>

>> >> 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.

>> >>

>> >> Having an organization to justify the need of resources doesn't block

>> any economic development in the region. It's actually the contrary.If

>> people are allowed to hold resources without any justification then they

>> will end up on the hands of those who can pay more and not on the hands of

>> those who really need them, making it more difficult for the internet to

>> progress in the region.

>> >>

>> >> Fernando

>> >>

>> >>

>> >>

>> >> 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>

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

>> >> A: 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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>> >>

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