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[rpd] Transfer Policy Proposal v.3.docx

JORDI PALET MARTINEZ jordi.palet at consulintel.es
Fri Oct 2 08:15:37 UTC 2020


Hi Mike,



Sorry the late response … a bit “too much” busy the last few weeks.



Even if the possible pillaging is small, we shall remember that:
Even just /22-/24 are needed for new operators or businesses to come into the Internet and be able to support IPv6-only networks with IPv4aaS. They need a small pool of IPv4 addresses. I’m not so much worried about existing ISPs, that have already much more space than that, because they could turn some of their existing IPv4 addresses from customers CPEs, into IPv6-only and keep growing or even go to the market and transfer addresses – they have resources (a new business usually don’t have so much financial resources and anything they can save matters).
Even if the AFRINIC pool is emptied, new addresses are coming from recovery, either via IANA or AFRINIC itself.


So, as much as we try to avoid bad practices, as much we lower costs for AFRINIC and the membership. Costs is not just about money and human rerouces, but also about time that the addresses can be reused instead of being reclaimed and quaranteened afterwards.



I was not alone in LACNIC, in fact, I was not participating in that too much compared with IPv6 proposals at that time. In fact, you should also recognize that when I introduced the Inter-RIR proposals (I presented 2 of them: legacy-only and comprehensive),  in the first version, the community reached consensus and recognized that a) it was the right time, b) my recommendation for a comprehensive proposal (versus a legacy only) reciprocal with all RIRs, what the right one.



Note the timing: LACNIC finally exhaused the pool last August. One month before the Inter-RIR proposal (which reached consensus one year before) was implemented (as said, it takes 1 year to implement such policy). I didn’t had the crystal ball, however, clearly we did in the right timing. I insist in “we”. I was just the author, the “community instrument”, but all this is always a community thing.



Regards,

Jordi

@jordipalet







El 28/9/20 20:04, "Mike Burns" <mike at iptrading.com> escribió:



Hello list,



I would like to provide some input from experience.

I brokered the world’s first inter-regional transfer back in 2012.

Since then we’ve brokered many hundreds of inter-regional transfers.

I also wrote the ARIN transfer policy which allowed for it to happen.



A significant policy change I made was the addition of a 12 month waiting period before any address-seller could access the remaining ARIN free pool.



Because at that point in time, although an inter-regional transfer policy was passed and ready to be implemented at ARIN, it was being blocked due to a particular concern. Which was that somebody in APNIC would demonstrate a need for addresses, which would be met by a willing ARIN seller. The APNIC buyer could immediately resell those addresses to somebody else in APNIC, and restore the buyer’s justified need. The ARIN seller, having sold his addresses, is now in need and could access the ARIN free pool to replenish. This action could be repeated by a pair of willing participants in APNIC and ARIN to effectively drain the remaining ARIN free pool. Yes it’s “fraud” but it was within policies at both RIRs.



This was the purpose of the 12 month waiting period on sellers—to prevent them from pillaging the remaining free pool. The situation is not exactly the same here at AFRINIC, but I think if the intent of the waiting period is to prevent sellers from acquiring addresses from AFRINIC in order to sell them, I support that. The limit should be on addresses acquired directly from AFRINIC, though, and not those purchased on the market, which I believe should be re-sellable without limitations in order to meet the varying business needs of market participants.



I doubt there will be anything left to pillage by the time this policy is implemented, but we should all be against the idea of a company acquiring addresses from AFRINIC by demonstrating need for them, only to turn around and sell them on the market.



Legacy addresses still provide the bulk of transfer sources. We don’t find them to be more attractive for most buyers because the benefits attached to legacy addresses are few, and the problems growing. The benefits are no RIR fees and no resale limits for RIPE legacy addresses. The problems are difficulties implementing RPKI on legacy space. The legacy issue is a side-issue, but I believe retaining legacy status after an inter-regional transfer INTO AFRINIC will incentivize some transfers. We know that buyers who prefer legacy space register that space in RIPE, and possibly those buyers would also look into AFRINIC registration should it be possible to retain legacy status.



I support the policy as written.

I would also support it with a 12-month wait because this will soon be moot.

I would also support it without the legacy status retention because this is a mild benefit at best.



Just get it done. The delays at LACNIC stretched on for years, with Inter-regional policy proposals being shot down over and over, more than once with the help of Jordi! But Jordi has seen the value of inter-regional transfers and the importance of a global market, and it should be clear to everybody that AFRINIC is now the only region placed outside that market.



Regards,
Mike Burns





From: JORDI PALET MARTINEZ via RPD <rpd at afrinic.net>
Sent: Monday, September 28, 2020 4:38 AM
To: rpd at afrinic.net
Subject: Re: [rpd] Transfer Policy Proposal v.3.docx



Responding to several emails at once …



I don’t agree with Fernando in the rush, I think is urgent to do something, but if we fail in the last call, it is just fine *if* the board agree to either make their own policy (according to the bylaws), or even better, make sure to have a focussed meeting on December (if this fails they still can do a policy). Obviously it is clear that I prefer that the community resolve it, but we can’t just wait anymore.



The economies are different, but basically they are different in the matter of the delay in what it happens, so yes, somehow LACNIC survived, and in part this was due to transfers under the table, which is a terrible thing to happen.



The Intra-RIR transfers will not resolve the problem, why, because operators and business in AFRICA are growing, and very few are moving to IPv6-only with IPv4aaS, so it is objectibely impossible that exisitng operators don’t need anymore IPv4 addresses and transfer them to new ones!



Now, regarding the point on “we can get this policy working” and then resolve the issues with another proposal … I will love to believe in that, but I’m every day more and more convinced that this will not happen. If we don’t get it right (or almost right on the first shot), we will not agree in 1 year to resolve it. I will love to be wrong!



The problem I see with this proposal is that there are key points that make it impossible to really work. We can’t enforce a non-existing and new template to other RIRs, we can’t enforce the source to call to the destination RIR and follow those policies, we can enforce a procedure that is telling AFRINIC how to do the things BUT we can’t enforcie the other RIRs to do the same. There are already 4 other RIRs which have agreed on how to do this, they have adjusted their systems one after the other to follow the first one (because it was a good procedure and was working). Is all about internal coordination systems among RIRs, which the policy doesn’t need to stated. I will agree that this is needed in a policy if we want to ask AFRINIC do to some specific steps which are only binding AFRINIC, but not other RIRs (I’m speaking here in general, not just for this policy).



Let’s say in another way. In any policy, if we let a RIR to decide about operational details and they fail, or it can be improved and they don’t do, then we, as a community, have the right to tell them “do this way”. Otherwise, is better that operational details are handled by the RIR.



Please, read my points in:

https://lists.afrinic.net/pipermail/rpd/2020/011429.html

https://lists.afrinic.net/pipermail/rpd/2020/011430.html



Those points aren’t issues that I think are wrong in terms of my “subjective view” on what should be an Inter-RIR policy (such as the hold-time and legacy when incoming). Those are objective aspects of the proposal that will avoid it to fly. It will require the other 4 RIRs to have *new* policies to comply with that. Do you really think this will happen, and in how much time? I don’t think adjusting those points change the authors and community intend, they are just required clarifications. The staff impact analysis already mention many of those.



Will love if the authors confirm if they will agree with those points, or otherwise, state one by one, why not.



And one more time, I think we all understand the problem statement. We should not base our debate on that. The 3 proposals are looking at the same and in that context, because the problem statement doesn’t go to the CPM is somehow irrelevant.



Regards,

Jordi

@jordipalet







El 28/9/20 4:15, "lucilla fornaro" <lucillafornarosawamoto at gmail.com> escribió:



dear all,





Without being catastrophic, I believe that the activities for which the African economy requires resources are mostly different from Latin America, and differently should be managed.



We cannot predict when it will happen, and this should be the main reason to solve the problem now that we have time to manage it properly.

The resource transfer policy proposed by Anthony and Taiwo aims to build a stable and effective resources management system for the Afrinic service region. If we start working for the resource problem now, no matter of issues that will potentially come up (like with any other policy), there will be space to improve them in the future.



regards,



Lucilla



Il giorno lun 28 set 2020 alle ore 10:02 Fernando Frediani <fhfrediani at gmail.com> ha scritto:

There is no "information" between quotes. If you don't believe in it check on LACNIC website on your own.

What a terrible scenario is painted here where it could be "terrible" not having a Inter-RIR transfer policy as soon as possible.
There is still IP space at a lower pace and there are internal transfers. Clearly a Inter-RIR transfer can wait a few more months in order to get it right rather than rush and get a bad policy. Co-Chairs deciding "the region needs a transfer policy" shows there is some rush in it that can be delayed if they re-think and bring it back to discussion to try to really find a rough consensus which is far form existing right now.

It is not correct this proposal "works very well". There are serious doubts, lacks confirmation from staff and other RIRs and there has been a very serious change in the very last minute not giving anyone else chance to discuss. So clearly this proposal is far from ready to reach consensus.

Fernando

On 26/09/2020 01:53, Ibeanusi Elvis wrote:

@Fernando,



If you are said you never mentioned not to do anything, what then are you implying by saying that “It took LACNIC 3years and 6months before they ran out completely”. So we should wait for ours to almost run out and drag the process along before we do something about it? This scenario is not as terrible? Rethink and review the scenario again, judging by the “information” you gave to us using LACNIC, it might not have been bad or terrible for them, but it might be for us. They might have survived but we might not. Put that into consideration as well.



Also, the Resource Transfer Policy proposed by Anthony and Taiwo works very well and there is no rush into anything.



The outcome might not be the same for everyone.



Elvis

Sent from my iPhone



On Sep 26, 2020, at 13:03, Fernando Frediani <fhfrediani at gmail.com> wrote:



I never mentioned "not do to anything", just to get the things right rather than rush,even if it takes a couple of more months.
It is much worst to get a bad policy than have none. The examples I put was to show that this scenario is not as terrible as some people are putting as almost if the internet was going to stop work if this policy doesn't advance.

Even if it takes a couple more of months to get that things right and out of this mess it will not be a big deal at all for the region.
It's not true this proposal works. It still lacks confirmations specially from other RIRs.
"Many more years" is of course an exaggeration on your side and we are talking about months rather than years which surely will not hurt.

The legacy stuff is currently like this: it loses its status, it is like this in other places as well which shows this is the obvious thing to keep. This was never mentioned in the discussion of this proposal for months and changed at the very last minute which gives no chance to others to equally oppose. If there is something to be discussed in another proposal is if the current status should change or not, not what is being trying to be done at rush.

There is no "forcing them to lose their legacy status". Whoever sell them don't care other than the money they receive. Whoever receives is only interested in the usage of the resources. What is being said about this is not correct how things really are in practical.

Fernando

On 26/09/2020 00:47, Ibeanusi Elvis wrote:

Dear Fernando,



"When LACNIC transitioned from Phase 2 to Phase 3 of the exhaustion phases which is very similar to what just happened to AfriNic Phase 2, it took exactly 3 years and 6 months for it to be completely empty”.



According to what you are insinuating, it is preferable not to do anything about the resources which are still going to exhaust. Thats makes no sense, it will be better if preparations are made prior to the entire exhaustion of the resources. LACNIC might have lasted 3 years and 6months before it completely emptied that does not mean we should take the same route as them, you learn from others not entirely copy their system or mode of handling things.



Additionally, “good or not organisation survived, found their way to work with this new scenario now there is a proper and well discussed proposal that works well for everybody and allow in and out transfer from ALL other RIRs”



The fact that the organisation survived does not 100% imply that if the same system of waiting till everything ends entirely is applied, AFRINIC will survive. It is best to take early necessary precautions and not wait till when we are in a desperate and maybe unsurvivable state before we do something. Also, this proposal is well detailed and works. Waiting for many more years and years of discussion is just compounding the staffs of the AFRINIC organisation and the community with excessive work as well.



Regarding the legacy resource holders, it is better to have a dedicated legacy proposal for them and work with them not forcing them to lose their legacy status.



Elvis





Consider that LACNIC has a much higher demand than AfriNic and during most of these 3 years it survived without a Inter-RIR policy that was discussed for quiet a while before it reached consensus, plus the time it took for it to be implemented by staff which happened just recently in middle of this year.On Sep 26, 2020, at 11:39, Fernando Frediani <fhfrediani at gmail.com> wrote:



A couple of information for those who are scary about "the pool be empty shortly".

When LACNIC transitioned from Phase 2 to Phase 3 of the exhaustion phases which is very similar to what just happened to AfriNic Phase 2, it took exactly 3 years and 6 months for it to be completely empty.
Consider that LACNIC has a much higher demand than AfriNic and during most of these 3 years it survived without a Inter-RIR policy that was discussed for quiet a while before it reached consensus, plus the time it took for it to be implemented by staff which happened just recently in middle of this year.

Good or not organizations survived, found their way to work with this new scenario e now there is a proper and well discussed proposal that work well for everybody and allow in and out transfer from ALL other RIRs. And by the way legacy resources lose its status like is expected.
And by the way, there is absolutely no "fight" with legacy resource holders, not at all. They don't care what will happen when they sell their resources on sold. Whoever is buying are not really much interested in this status, but in acquiring them for their usage and that's it.

AfriNic can take some more time, specially in the current uncertainty scenario to get a proper and better discussed proposal that will in fact be reciprocal to all other RIRs and benefit the region to keep going after the pool is completely empty which still takes some time.

Fernando

On 25/09/2020 22:08, lucilla fornaro wrote:

Dear all,



Accepting this policy implies that AFRINIC will develop a way to get even more resources to satisfy and push the demand of the developing market.

We often talked about smoother business (why the community is so scared about this word?) operations, the policy does not facilitate any fraud. All resources are allocated and transferred in the base of a proven need. It is an expensive process, and it is reasonable to think that no one would operate a fraud that causes loss instead of benefits.



Yes, shortly the pool will be empty, but the policy proposes a way to fight it and promote access to further resources before it's too late.



regards,



Lucilla



Il giorno sab 26 set 2020 alle ore 09:49 Ibeanusi Elvis <ibeanusielvis at gmail.com> ha scritto:

Dear Marcus, Dear Community,



I do not concur with your analogy and accusations on the proposal or policy written by Anthony Ikechukwu Ubah and Taiwo Oyewande called “Resource Transfer Policy” as being a hindrance to the smooth operation of business, is entirely false. The major intention of this policy is to support and boost businesses i Africa not to hinder the operation of business.



Likewise, the policy is not based on a fake problem of the African region. This is baseless accusation and a wrong self-interpretation of what factual intentions of the Resource Transfer Policy, Anthony and Taiwo should be appreciated for pointing out this issue.



On the other hand, "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.”



The purpose of this policy is to support a “TWO-WAY INTER-RIR POLICY” which implies that AFRINIC can receive and transfer resources. With the exhaustion of the IPv4, the adoption of this policy will do a greater good to the African continent as it supports the circulation of resources into and out of all the RIRs



Best,

Elvis



On Sep 26, 2020, at 02:24, Taiwo Oyewande <taiwo.oyewande88 at gmail.com> wrote:



Hi all,



Discussing a problem statement that will not be implemented in the CPM is not really taking us forward.



There is an obvious war against the co chairs for doing a job that the community mandated them to do by the status of their election. The co-chairs discussed each points raised with the various authors and tried to see if all the points were duly addressed before making their decisions.



I saw a false and misleading statement about the cochairs trying to get the authors of 2 of the 3 related policies against the authors of the 3rd policy. Is this what members of this working group has turned to?

Trying to create a bad name for another member using scenarios that never occurred. I think that is the height of desperation and such defamation of character should not be encouraged on this list



Taiwo



On 25 Sep 2020, at 14:17, 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> 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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