[rpd] Transfer Policy Proposal v.3.docx

[Ekaterina Kalugina]

Dear Marcus, dear all,

I think this argument is problematic for the following reasons.

First of all, Anthony's and Taiwo's policy is NOT based on a fake problem.
The current scarcity of resources AFRINIC is already limiting business
growth in the region considering that the allocation size is currently a
mere /22. As the current policy is not providing adequate ways of
replenishing the resources, it ought to be amended.

Secondly, since in the nearest future the pool will be empty, we must
secure ways of import before its too late and the economy of region is
affected. What do you think would happen if businesses cannot receive the
IP resources they need to operate? How do you think it would impact the
development and growth of the region now, when 90% of all business
operation has moved online because of Covid?

Thirdly, smooth business operation would mean that the supply of resources
is steadily growing together with the demand. In order to meet such demand,
a viable import policy must be implemented as soon as possible. I do not
need to be an author of this policy to understand its vital importance and
its impact.

Fourthly, like you said, "Africa is at its developing stage and needs more
internet resources to support its developing process." Accepting this
policy does not mean that the African resources will be taken away.
Accepting this policy means that AFRINIC will have a way to get MORE
resources to meet the demand of the developing economy. There is no
necessity to have an audit mechanism in place - all resources are already
being allocated and transfer in the base of a proven need. In case of
fraud, the resources will be simply recalled and the contracts will be
terminated.

Allowing the global market to trade freely is one of the basic requirements
for steady economic development. There is no way, anyone, especially
AFRINIC, can ever dream of controlling it. We just need to focus on taking
advantage of it. And this is exactly what the proposed Resource Transfer
Policy seeks to accomplish.

Best wishes,

Kay

On Fri, 25 Sep 2020, 15:15 Marcus K. G. Adomey <madomey at hotmail.com> wrote:


> Dear all,

>

> The Policy “Resource Transfer Policy” (AFPUB-2019-V4-003-DRAFT01) proposed

> by Anthony Ikechukwu Ubah and Taiwo Oyewande is based on a fake problem for

> our region.

>

>

> (1) “The current policy fails to support a two-way Inter-RIR policy” – And

> so what? This was an intra-RIR transfer policy, not meant to be Inter-RIR

>

> (2) “there by hindering smooth business operation”

>

> Can the authors of the policy show how the current situation is “hindering

> smooth business operation?”

>

> Further, they should tell us what they mean by “smooth business operation”.

>

> (3) “development and growth in the region”

>

> Can the authors of the policy prove that the current status is hindering

> “development and growth in the region”?

>

> It is clear that the authors of the policy have used unsubstantiated

> claims to buttress the need for this policy.

>

> Basically, the Resource Transfer Policy is intended to take Internet

> Resources on one region to the other. We all know that Africa is at its

> developing stage and needs more internet resources to support its

> developmental process. Accepting this policy means that the little

> resources left in our region will be taken away, especially when we don’t

> have the mechanism in place to enforce the auditing of the use of the

> allocated resources.

>

> Moreover, any unmanaged inter-RIR transfer policy will weaken the

> development of the Internet in the region as we have no control over this

> global market which never played in our favor. It may also affect AFRINIC

> operations.

>

> Recent findings discussed on this list show how transferred resources are

> being used. The global community is yet to discuss the impact on transfer.

> I am more concerned for our region.

>

> Reconsider your decision and let us discuss the best approach to engage

> the Region into the global resources transfer world.

>

>

>

> Marcus

>

>

>

>

>

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

> *From:* Murungi Daniel <dmurungi at wia.co.tz>

> *Sent:* Wednesday, September 23, 2020 8:59 PM

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

> *Subject:* Re: [rpd] Transfer Policy Proposal v.3.docx

>

> Hello,

>

> Can the authors of the resource transfer policy in the last call explain,

> which problem is being addressed?

>

> The problem statement is awkward to say the least. The issue with the

> problem statement was raised in Luanda and during the virtual AIS. How can

> we can adopt a proposal when the problem statement is out of scope of the

> PDP?

>

> ——-

> 1. Summary of the problem being addressed by this proposal

> The current policy fails to support a two-way Inter-RIR policy, thereby

> hindering smooth business operation, development, and growth in the region.

> This proposal aims to establish an efficient and business-friendly

> mechanism to allow a number of resources to be transferred from/to other

> regions. This proposal outlines a model in which AFRINIC can freely

> transfer number resources to/from other regions, i.e. RIPE NCC, APNIC, ARIN

> and LACNIC. This includes both IPv4 addresses and AS numbers.

> ——-

>

>

> Regards,

>

> Murungi Daniel

>

>

>

> On Sep 23, 2020, at 10:39 PM, Fernando Frediani <fhfrediani at gmail.com>

> wrote:

>

> Hello

>

> There is no much I can do other than state my *opposition to this

> proposal* to advance and reach any consensus mainly because 5.7.4.3 has

> been inverted from what was originally in the proposal and only changed at

> last minute due to some comments in the PPM going straight to last call

> which didn't give opportunity to the community re-evaluate this major

> change and if it's suitable to the region or not.

>

> Co-Chairs cannot advance this proposal to rough consensus the way it is

> and I urge and ask them again to bring it back to discussion to find out a

> resolution to these opened issues. Multiple people raised substantial

> concerns about it already. There is no way it can be considered 'rough

> consensus'.

>

> I also understand there may be a hurry to get a Inter-RIR transfer policy

> as soon as possible, but we must care about what is most important than

> that which is get policies to reflect what is really good for the region

> and not just to a few actors, even if it takes a bit longer. I support

> Jordi's suggestion to have another PPM in a few months so perhaps this

> proposal can advance from that point in time. LACNIC remained about 2 years

> without a Inter-RIR transfer policy after it run out of addresses for new

> organizations and survived. AfriNic will survive if it has to wait a few

> more months in order to get things really right.

>

> Now going to the merit of the proposal specially the main point I oppose

> (5.7.4.3):

> There is no sense at all to keep considering transferred legacy resources

> as legacy. This doesn't work that way and has a proper reason to be like

> that which is fix a historical internet problem and reduce legacy resources

> with time as they get transferred to 'normal' organizations who purchased

> them in the market for example.

> In this way organizations receiving these resources are bind to the same

> rules everybody else making it much fair to everybody and making no

> distinction between members.

> Allowing resources to remain considered legacy only contributed to abuses

> and unfairness allowing those who can pay more do whatever they like which

> is bad for the rest of the Internet community which are subject to the same

> rules  that apply equally to them.

> If transferred legacy resources are not considered legacy anymore more and

> more they will apply equally for everybody as they become as a normal

> resource within any RIR. There has been a strong reason for this be like

> that until now and to continue like that.

>

> Regards

> Fernando

> On 23/09/2020 09:49, JORDI PALET MARTINEZ via RPD wrote:

>

> Hi Taiwo, all,

>

> I've looked into the doc.

>

> Let me say something before going into a more detailed analysis: I *fully support* this proposal, and I will be happy to withdraw it once:

> 1) The staff confirms that all the points on the staff analysis have been cleared and thus, the policy could be implemented and will be functional in the intended purpose.

> 2) The board ratifies the policy (which means also it passes the last call).

>

> Why? If anything in the process fails, I still believe my proposal is clearer and never mind is my proposal or this one I'm happy to work with the authors to make sure to resolve the issues that may happen as indicated in 1 and 2 above (hopefully there are no issues).

>

> I've now a more detailed analysis, please really, needs to be taken seriously with the staff or we may ruin the policy and not allow to be functional.

>

> There is something which doesn't make sense: The text in point 5.7. The CPM should be read always as "actual" so "soon will exhaust ..." is not logic, neither needed for the purpose of this policy. In addition, there are typos there ...

>

> This is an editorial change that according to the PDP should be possible as part of the last call. I will suggest to keep it simple:

> 5.7 IPv4 Resources transfer

> This policy applies to an organization with a justified need for IPv4 resources (recipients) and organizations with IPv4 resources which no longer need (sources).

>

> I see that the "disputes" issue has been resolved! Tks! Anyway, I think there is another editorial problem there.

> Actual text:

> 5.7.3.1 The source must be the current rightful holder of the IPv4 address resources registered with any RIR, and shall be in compliance with the policies of the receiving RIR, and shall not be involved in any dispute as to the status of those resources.

>

> I suggest:

> 5.7.3.1 The source must be the current rightful holder of the IPv4 address resources registered with any RIR, in compliance with the relevant policies, and shall not be involved in any dispute as to the status of those resources.

>

> Keeping the "policies of the receiving RIR" is contradictory ... changing it with "relevant policies" allows both RIRs to ensure that everything is correct.

>

> Grammar maybe, I'm not English native speaker:

> "for 12 months period" or "for a 12 months period"

>

> I think 5.7.3.3. doesn't add any value, it could be removed and doesn't change anything: if there is no limite, no need to mention it. If there is not agreement, clearly the transfer will not happen because the parties don't authorize it, and then the RIR(s) don't authorize it!

>

> Similarly 5.7.4.2. could be removed as well. We already said that the recipient should comply with policies (5.7.3.1), so what is this adding? Just superfluous text.

>

> Note also my imputs in the previous email, regarding the hold period and the legacy status. I think 5.7.4.3, should be "IPv4 legacy resources "Transferred incoming or within AFRINIC IPv4 legacy resources will no longer be regarded as legacy resources".

>

> 5.7.5.1 is already indicated by the staff as something problematic with the actual wording. The transferring party (the source) may not have any relation (not a member) with the receiving RIR. With this text we are enforcing *all the RIRs* to offer a standard template and process on our mandate. WE CAN'T DO THAT. Our policies only have a mandate in AFRINIC, not in the other RIRs.

>

> If we just remove section 5.7.5, and leave it to the staff as part of the operational procedure, the the problem is resolved because the existing process among the all other 4 RIRs for transfers will be "joined" by AFRINIC. It is just a matter of interconection among systems and processes!

>

> I think all this should be carefully studied among the authors and the staff and the chairs should make sure that the verstion coming to last call has corrected all those issues.

>

> I hope all this is useful.

>

> Regards,

> Jordi

> @jordipalet

>

>

>

> El 23/9/20 9:38, "Taiwo Oyewande" <taiwo.oyewande88 at gmail.com> <taiwo.oyewande88 at gmail.com> escribió:

>

>     Hello PDWG,

>

>     Attached is the updated version of the Resource Transfer Policy proposal. As recommended, changes have been effected on sub-section  5.7.3.2, and 5.7.4.3 according to the co-chair summary.

>

>

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