[rpd] AFRINIC Number Resources Transfer Policy Version 1.0

[Ekaterina Kalugina]

Dear Noah, dear community,

The main reason for introducing a new version of the draft policy is to
address the major objections raised by the community in regards to the
previous one. However, from what I see here, the purposed policy did not
address any of the major objections raised in the last PPM. In particular,
let me quote the summary of the chairs here:

"AFRINIC Number Resource Transfer

a.                   Not realistic for one-way inter RIR resource transfer
as it has to be reciprocal. One way would never happen as only global
resources can come in and go out

b.                  It would be difficult for the recipient to follow the
rules of AFRINIC if they are not in the African region.

c.                   No need for ASN transfer. If one is moving regions and
doesn't have an ASN in the new region, it can request and receive from the
local RIRs

d.                  Additional attributes create none-operational
complexity in the whois database."

If these objections are not addressed, the policy will be rejected again
for the same reasons. So, frankly speaking, I do not see why you would put
forward such a proposal. It will end up in a deadlock and just waste the
time of everybody involved.

Best,

Ekaterina

On Sat, 17 Oct 2020, 15:03 Noah <noah at neo.co.tz> wrote:


> Dear Working Group/Co-Chairs,

>

> A new policy proposal  named "AFRINIC resources transfer policy" is

> submitted for discussions. This proposal obsoletes the current  IPv4

> transfer within AFRINIC  service region policy, defines rules for transfers

> of IPv4 and ASNs within the region and between the AFRINIC service region

> and other regions.

>

> The policy allows a category of resources to be transferred out of the

> region, another category of resources to be transferred inside and denies

> the transfer of certain resources.

>

> We expect this to be a response to a harmonised policy which addresses

> some of the limitations of the intra-rir policy and proposes a solution for

> an inter-rir transfer  which minimizes the foreseen risks of uncontrolled

> outflow of resources.

>

> Please find the proposals text below and also attached pdf format.

>

> Happiest Weekend,

> Noah on behalf of

> The Co-authors

>

>

> ================================================================

>

> Policy Name: *AFRINIC Number Resources Transfer Policy*

> ID: (Assigned by AFRINIC)

> Submission *Date: 17 Oct 2020*

> Version: 1.0

> Author(s): (a) Name, (b) Email address, (c) Affiliation, if applicable

>       Gregoire Olaotan Ehoumi, gregoire at ehoumi.net, independent

>       Noah  Maina, noah.maina at seacom.com, SEACOM

>       Adeola A. P. Aina, alain.aina at wacren.net, WACREN

>

>

> *Sections of Policy Manual affected*

> *Obsoletes*: IPv4 Resources transfer within the AFRINIC Region (Section

> 5.7 of the CPM)

>

> *1.0 Summary of the problem being addressed by this proposal*

>

> The AFRINIC IPv4 pool is expected to run out soon. Some entities may need

> IPv4 space to support their IPv6 deployments, especially to support

> transition mechanisms, which AFRINIC may not meet. The current Intra-RIR

> policy in force at AFRINIC allows entities to receive unused IPv4 addresses

> from other members solely within the AFRINIC region, based on justified

> needs. Considering the limited IPv4 space initially made available to

> AFRINIC (AFRINIC manages only 7.23 /8s with a very low ratio of IPv4

> addresses per Internet user), there will therefore be a need to allow for

> unused IPv4 from other regions to move into the AFRINIC service region °V

> this without necessarily depleting AFRINIC's slim amount of IPv4 addresses

> by transferring space out of the region. The current Intra-RIR transfer

> policy allows all types of IPv4 allocations/assignments to be transferred,

> including IPv4 from special purpose blocks (reserved blocks for IXPs and

> DNS root ops, Last /8, etc.) The current intra-RIR transfer policy does not

> cover ASNs while there are cases where transfers of ASNs among AFRINIC

> members is desirable.

>

>

> *2.0 Summary of how this proposal addresses the problem*

>

> This new policy defines a set of rules to allow transfer of IPv4 addresses

> and ASNs within the AFRINIC service region; and between the AFRINIC service

> region and other regions by specifying what categories of resources are

> eligible for transfer, the location of parties (sources and recipients) and

> the conditions to be met.

> The policy segregates resources in different categories and defines which

> transfer rules apply to each category.

> Only Legacy resources and resources transferred in from other regions will

> be transferable out of the AFRINIC service region.

> The policy also makes the following provisions:

> - Number resources are non-transferable unless AFRINIC has expressly and

> in writing approved a request for transfer. AFRINIC is tasked with making

> prudent decisions on whether to approve the transfer of number resources.

> - IPv4 addresses and ASNs can be transferred only in accordance with this

> policy.

> - AFRINIC does not recognize transfers outside of approved transfer

> policies and requires organizations holding such resources to return them

> to the appropriate registries.

> The goal of this transfer policy is to help distribute resources from

> those who no longer need them to organizations that need the resources, but

> cannot obtain them from the AFRINIC free pools.

> AFRINIC recognizes the following types of transfers:

> - merger, acquisition, takeover or consolidation,

> - between AFRINIC members,

> - between an AFRINIC member and an organization in another region,

> - between a Legacy resource holder and an AFRINIC member,

> - between a Legacy resource holder and an organization in another region.

> AFRINIC will process and record Inter-RIR resource transfers only when the

> counterpart RIR has an Inter-RIR transfer policy that permits the transfer

> of IPv4 address space and ASNs between its own region and AFRINIC.

> Currently, the other regions are APNIC, ARIN, LACNIC, RIPE NCC.

>

> *3.0 Proposal*

>

> Insert the following text into the CPM (numbering to be changed by staff

> as appropriate):

> 3.1 Definitions

> 3.1.1 "Resource" refers to IPv4 Address space or Autonomous System Numbers.

> "AFRINIC pool" means the AFRINIC managed pool of IPv4 and ASNs, obtained

> from IANA (allocated and recovered) or through the ERX (Early registration

> transfers).

> 3.1.2 "Special-Purpose pool" means the pool of resources currently

> reserved for Critical Internet Infrastructures (section 5.6.4 of CPM) and

> resources distributed during the Exhaustion phases of the soft landing

> policy (section 5.4 of CPM).

> 3.1.3 "Legacy resources" refer to resources allocated prior to the RIR

> system and tagged as Legacy by AFRINIC.

> 3.1.4 "Others" means resources transferred from other regions through

> Inter-RIR transfers.

> 3.1.5 "Inter-RIR transfer" means the transfer of resources from a resource

> holder in the AFRINIC service region to an organization in another region

> or vice-versa.

>

> *3.2 Marking of the resources*

> AFRINIC pool == Regional

> Special-Purpose pool == Reserved

> Legacy == Legacy

> Others == Global

>

> *3.3 Rules and procedures for selecting resources eligible for transfers*

> 3.3.1 If source and recipient are AFRINIC members, then allow "Regional",

> "Global" or "Legacy" for transfer and mark transferred "Legacy" as "Global".

> 3.3.2 If source is Legacy holder and recipient is AFRINIC member, then

> allow "Legacy" for transfer and mark transferred resources as "Global".

> 3.3.3 If source is Legacy holder and recipient is in another region, then

> allow "Legacy" for transfer.

> 3.3.4 If source is AFRINIC member and recipient is in another region, then

> allow "Global" for transfer.

> 3.3.5 If source is from another region and recipient is AFRINIC member,

> then allow "Any", and then mark the transferred resources as "Global".

> 3.3.6 Irrespective of the source and recipient, if the resource to be

> transferred is "Reserved" then deny transfer. This restriction excludes

> mergers, acquisitions and takeover transfers.

>

> *3.4 Conditions on resources to be transferred*

> - The size of the IPv4 address prefix should be a minimum of /24.

> - The resource must qualify for the type of transfer requested.

> - The resource will be covered by AFRINIC policies after transfer into the

> region.

>

>

> *3.5 Conditions on the source*- Must be the right holder of the resources

> to be transferred with no disputes.

> - If the source is from other regions, conditions on the source are

> defined in the counterpart RIRs transfer policy.

>

> *3.6 Conditions on the recipient*

> - Will be subject to current AFRINIC policies.

> -  Must sign RSA.

> - Recipient that does not have prior resources must:

> ++ demonstrate a detailed plan for the use of the transferred resources

> (in the case of ASN, the recipient must meet the criteria for assignment

> of ASN).

> - Recipient with prior resources must:

> ++ demonstrate a detailed plan for the use of the transferred resources

> (in the case of ASN, the recipient must meet the criteria for assignment

> of ASN).

> ++ Show past usage rate.

> ++ Provide evidence of compliance with AFRINIC policies with respect to

> past allocations/assignments.

> - If the recipient is in another region, the conditions on the recipient

> are defined in the counterparts RIR transfer policy.

>

> * 4. References*

>

> https://www.nro.net/wp-content/uploads/NRO-Statistics-2019Q2.pdf

> https://www.potaroo.net/tools/ipv4/

> https://bgp.potaroo.net/iso3166/v4cc.html

> https://resources.potaroo.net/iso3166/ascc.html

> ftp://ftp.afrinic.net/stats/afrinic/transfers/

>

> ================================================================

>

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