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

[JORDI PALET MARTINEZ]

Hi Marius,

 

I’m not sure if you see my point.

 

If an operator decides to transfer resources is because he has decided that no longer needs them.

 

If he can obtain resources again from AFRINIC, it is really simple to justify the need, for example:

 
I’ve customers, I want to provide 1 (or even more than 1), public IP to every customer. I want to use public IPs for all the point to point links, etc. All this is a *perfect valid justification*.
I transfer the addresses (I get money because it is cheaper getting addresses from AFRINIC), and use now private IPs for customers, with CGN or something else.
Now I go to AFRINIC and ask again for addresses “I changed my mind” … and keep repeating this.
And all this takes more and more human resources from AFRINIC to evaluate each case.
 

There is a limit on what AFRINIC can’t accept on justified need. Trying to fix that in policies is much more complex that setting a cold-down time, so it discourages who is trying to justify need just to make business transferring once and again addresses.

 

A hold-down period means AFRINIC don’t need to waste resources in evaluation of need for whom has already transferred their own resources, at least for a while.

 

Possible case against this way:
I discover that I’ve excess of resources. I want to transfer them and I do.
Suddenly my network needs again more resources, the hold-down time is against me, I need to wait “n” months.
 

While I think this is possible, I think is an extreme corner case, because *you should do a proper planning before transferring*, you should move to IPv6 (so even if you network grows you need less and less IPv4 resources, not more). And of course, neither AFRINIC neither the community should be responsible if you aren’t running your business in the right direction with appropriate planning, otherwise AFRINIC will be also accountable for many other “business” decisions related to policies!

 

I think this extreme case, if it happens, is acceptable for the good of the community vs AFRINIC having a much higher evaluation costs/resources and more chances of abuse.

 

Regards,

Jordi

@jordipalet

 

 

 

El 18/9/20 10:05, "Marius Andioc via RPD" <rpd at afrinic.net> escribió:

 

Dear Jordi, 

 

This would be the case if there was absolutely no safeguard, which is not the case. 

 

Transfer and Allocation policies are both need based, which implies for both source and entities to be able to justify their transfers. If one asks for new resources after just transferring them, it will need to justify its needs in a very different context than one who didn't transfer. Justifying a need of resources will be more demanding as being in the position of transferring makes you suspicious. 

 

I think the need requirements are sufficient safeguards and we should preserve a mechanism as simple as possible to allocate resources efficiently. 

 

Best regards, 

 

Marius 

 

 

Le 18 sept. 2020 00:12, JORDI PALET MARTINEZ via RPD <rpd at afrinic.net> a écrit :

I disagree.

 

Having no “wait” time to get new resources, is prone to abuse.

 

Having no “hold” time, once to received AFRINIC resources, to transfer them, is prone to abuse.

 

It is rationally impossible to justify otherwise.

 

Regards,

Jordi

@jordipalet

 

 

 

El 17/9/20 9:11, "lucilla fornaro" <lucillafornarosawamoto at gmail.com> escribió:

 

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

>>

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>>

>>

>>

>>

>> 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

>>

>>

>>

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>> 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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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.

 

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