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[rpd] [pdwg] AFRINIC Number Resources Transfer Policy Version 1.0

Fernando Frediani fhfrediani at gmail.com
Tue Oct 27 12:58:02 UTC 2020


I agree with Jordi's and Noah's messages in the sense Co-Chairs cannot 
hold the publishing of a new proposal despite their personal beliefs. If 
there are/will be issues with the new proposal that will be discussed 
afterwards by the Working Group and I also ask the Co-Chairs to let it 
go its natural path and not set this precedent.

Regards
Fernando

On 27/10/2020 07:57, JORDI PALET MARTINEZ via RPD wrote:
>
> Hi AK,
>
> I disagree. “The draft policy shall be …” then you have “The Working 
> Group Chair(s) may …”.
>
> Note the order, this is plain English. You need to **do** in the 
> stated order, not a different one.
>
> And you are missing the previous text in 3.4 which states:
>
> “Anyone can submit a proposal. Policy proposals are submitted to the 
> Resource Policy Discussion mailing list (rpd at afrinic.net 
> <mailto:rpd at afrinic.net>) by the author. AFRINIC will provide 
> administrative support and assist the author(s) in drafting the 
> proposal if requested. AFRINIC shall also provide relevant facts and 
> statistics if requested during the discussion.”
>
> And you are also missing 3.4.1 previous paragraph:
>
> “During the development of policy, draft versions of the document are 
> made available for review and comment by publishing them on the 
> AFRINIC website and posting them to the rpd at afrinic.net 
> <mailto:rpd at afrinic.net> mailing list. Each draft policy is assigned a 
> unique identifier by AFRINIC and the AFRINIC website shall also 
> contain the version history and the status of all proposals.”
>
> So, the order is:
>
>  1. Authors send a proposal. AFRINIC staff (not co-chairs) could offer
>     support.
>  2. AFRINIC staff shall assign an identifies and publish in the web site.
>  3. Co-chairs could ask the staff for inputs (which it is actually
>     done by default by staff already – analysis impact). But of
>     course, co-chairs can ask for further clarifications, etc.
>
> The order is **extremely relevant** and if you change it, you violate 
> the CPM. As you said, it is written in clear english!
>
> The PDP is our law and the interpretation is only possible **following 
> the strict order**. Reordering means breaking it as it happens with 
> any law!
>
> An example (a bit exagerated so is easier to see), if you have a law 
> for speed limit in the road:
>
>  1. The driving speed limit in this road is 100 Km/h.
>  2. You get a fine.
>
> If you change the order, the consequence is clear, you get a fine, 
> even if you aren’t over the speed limit!
>
> You said “*As an author of so many proposals yourself, you know quite 
> well that it takes some time to process this thing and announce on the 
> mailing list*”. Yes, what I do is to use the staff (staff, not 
> co-chairs) path, because I agree that a proposal in the web site is 
> **easier** to read, the staff can already provide the proposal 
> indentifier, some times they may discover a typo, or do some 
> suggestions, etc., and there **usually** there is no need to hurry up 
> with the annoucement in the list. However what I’m doing, voluntarely 
> is not a **must** for all the proposals/authors which follow the CPM 
> just by sending it straitht to the list.
>
> Sometimes, in fact, I should said that this “publication” process is 
> extremely slow, and should not be like that. The staff should be able 
> to publish a proposal even if there were one every other day (which 
> clearly is not the case, I’m just exigerating), because the time it 
> takes to a) assign and ID, b) make it in the policy proposal web page, 
> **realistically** takes just **minutes**.
>
> I also suggested the staff some time ago, they this can be simplified 
> by an automated form (like LACNIC and APNIC is doing), which (if there 
> is no inputs from the staff), could just mean the staf just need to 
> “click” on the “publish” button to actually make it happen.
>
> I fully understand that this is not your day job, and fully recognize 
> it, and I’m very thankful for that. I’ve said this many times: I 
> prefer to send another 100 proposals before being a co-chair. However, 
> this part of the process is for the **staff** not the co-chairs, so 
> even if you have **any** reservation, you can’t do anything about 
> that, you **can’t interfere** with this part of the process. Doing so 
> it is plain blatant wrong.
>
> Regards,
>
> Jordi
>
> @jordipalet
>
> El 27/10/20 10:48, "ABDULKARIM OLOYEDE" <oloyede.aa at unilorin.edu.ng 
> <mailto:oloyede.aa at unilorin.edu.ng>> escribió:
>
> Dear Jordi,
>
> Thanks for your mail. However, the section is not broken, it was 
> written in clear English.
>
> Please read it again.
>
> The draft policy shall be available for review for at least four weeks 
> before the next Public Policy Meeting. The author(s) shall make the 
> necessary changes to the draft policy according to the feedback 
> received. *The Working Group Chair(s) may request AFRINIC to provide 
> an analysis (technical, financial, legal or other), of the impact of 
> the draft policy proposal.***
>
> *Please note however that we never said we are not going to publish 
> this proposal.  As an author of so many proposals yourself, you know 
> quite well that it takes some time to process this thing and announce 
> on the mailing list. We don't work on these things full time and we 
> get busy too some times.  We have also had a meeting with you in the 
> past before publishing one of your proposals. You know how this thing 
> works sometimes. *
>
> *Yes, we have a reservation about this proposal because of a competing 
> proposal is on the last call which is not an everyday situation 
> therefore it requires that we look into it carefully. *
>
> *We would publish it as required by the CPM we only wanted to 
> understand its impact on the community's time so that we can allow the 
> community to make an informed decision about it. *
>
> *Please let us be patient and not jump into a quick conclusion. *
>
> Co-Chair
>
> PDWG
>
> On Tue, Oct 27, 2020 at 10:05 AM JORDI PALET MARTINEZ via RPD 
> <rpd at afrinic.net <mailto:rpd at afrinic.net>> wrote:
>
>     Hi AK, all,
>
>     This is a totally broken interpretation of the PDP.
>
>     Section 3.4.1 is referring to ask for an impact analysis **after**
>     a proposal has been submitted and published.
>
>     The PDP doesn’t allow the chairs to “hold” the publication of
>     **any** proposal.
>
>     The PDP, doesn’t disallow having competing proposals, **never
>     mind** they are in any phase or even if they are “competing” with
>     a ratified proposal.
>
>     In fact, that’s part of the PDP!
>
>     We may have a policy, let’s suppose we have already and Inter-RIR
>     policy, and part of the community things is wrong. They have the
>     right to present another proposal to amend it.
>
>     It is just fine, and I will say very good, if you want to
>     coordinate among different competing proposals authors to come
>     together. Do you remember I asked for this before the Luanda
>     meeting? But **that** can’t be used as an excuse to **hold** the
>     publication of any proposal.
>
>     Regards,
>
>     Jordi
>
>     @jordipalet
>
>     El 27/10/20 6:56, "ABDULKARIM OLOYEDE" <oloyede.aa at unilorin.edu.ng
>     <mailto:oloyede.aa at unilorin.edu.ng>> escribió:
>
>     Dear Noah,
>
>     A Section of 3.4.1 of the CPM reads ... "The Working Group
>     Chair(s) may request AFRINIC to provide an analysis (technical,
>     financial, legal or other), of the impact of the draft policy
>     proposal..."
>
>     We are in the process of asking AFRINIC to provide us with
>     an analysis/advice of how to handle this proposal since a
>     competing proposal is already in the last call.
>
>     The community is made up of volunteers whose time are very
>     precious. We want to reduce community burnout as much as we can
>     and avoid wasting any one's time. You would agree with me that if
>     the proposal in the last call is ratified then discussing this
>     other one would amount to a waste of time. We have earlier
>     received an analysis/advice on this issue and we this morning
>     received a more detailed analysis/advice on how to proceed with
>     this proposal and we would like to discuss this with you (the
>     authors) so that we are all on the same page going forward. 
>     Please give us a time that is most suitable for you (the authors)
>     and we arrange a zoom meeting.
>
>     In the meantime, we shall continue to carry out the necessary
>     background work on this proposal.
>
>     Please accept our apologies for any delay in communicating this to
>     you.
>
>      Thanks
>
>     Co-Chair
>
>     PDWG
>
>     On Mon, Oct 26, 2020 at 1:25 PM Noah <noah at neo.co.tz
>     <mailto:noah at neo.co.tz>> wrote:
>
>         Hi Co-chairs,
>
>         The PDP does not allow Co-chairs to approve draft proposals
>         submitted to the WG.
>
>         The draft proposal has been submitted and is under discussion
>         as per section 3.4 of the CPM and must be published by AFRINIC
>         staff.
>
>         Can you please tell the WG what you want to discuss with the
>         authors during this call which we did try to discuss openly
>         after you rejected our motivated submission for version 3.0
>         with the reasons being that the proposal had expired.
>
>         Cheers,
>
>         *./noah*
>
>         neo - network engineering and operations
>
>         On Mon, Oct 26, 2020 at 7:31 AM ABDULKARIM OLOYEDE
>         <oloyede.aa at unilorin.edu.ng
>         <mailto:oloyede.aa at unilorin.edu.ng>> wrote:
>
>             Dear Noah,
>
>             It is not yet published because we are still looking into
>             it and we are planning a meeting with the Authors sometime
>             soon.
>
>             Thanks and Regards
>
>             Co-Chair
>
>             PDWG
>
>             On Sun, 25 Oct 2020, 19:20 Noah via pdwg,
>             <pdwg at afrinic.net <mailto:pdwg at afrinic.net>> wrote:
>
>                 Attention PDWG Co-chairs,
>
>                 Any reason this proposal has not been posted online on
>                 the AFRINIC website?
>
>                 *./noah*
>
>                 neo - network engineering and operations
>
>                 On Sat, Oct 17, 2020 at 4:03 PM Noah <noah at neo.co.tz
>                 <mailto: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
>                     <mailto:gregoire at ehoumi.net>, independent
>                           Noah  Maina, noah.maina at seacom.com
>                     <mailto:noah.maina at seacom.com>, SEACOM
>                           Adeola A. P. Aina, alain.aina at wacren.net
>                     <mailto: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.nro.net/wp-content/uploads/NRO-Statistics-2019Q2.pdf>
>                     https://www.potaroo.net/tools/ipv4/
>                     <https://www.potaroo.net/tools/ipv4/>
>                     https://bgp.potaroo.net/iso3166/v4cc.html
>                     <https://bgp.potaroo.net/iso3166/v4cc.html>
>                     https://resources.potaroo.net/iso3166/ascc.html
>                     <https://resources.potaroo.net/iso3166/ascc.html>
>                     ftp://ftp.afrinic.net/stats/afrinic/transfers/
>                     <ftp://ftp.afrinic.net/stats/afrinic/transfers/>
>
>                     ================================================================
>
>                 _______________________________________________
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