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[rpd] [Community-Discuss] Unaddressed queries by AFRINIC during AGMM

Owen DeLong owen at
Wed Jul 14 09:58:09 UTC 2021

> On Jul 2, 2021, at 13:26 , Fernando Frediani <fhfrediani at> wrote:


> Perhaps you may not be used with the way numbering resources are allocated and must be used. This is not a simple internal network usage thing that any company can decide at will.


Per haps you are not familiar with how number resource policies work, since you continue to make incorrect statements about it as if they are fact.

> Anyone holding these resources MUST use them in according to the current rules and MUST justify and *keep justifying that usage* permanently in order to be able to keep holding those resources - which by the way is not something the belongs to the organization.


Sure, but the current rules are the ones written in the bylaws, the RSA, and the CPM. So in order to claim that leasing is a violation of the rules, you have to show some section of at least one of those documents that actually prohibits it. Otherwise, it’s not a violation of policy.

> Bizarre is to get resources form the RIR, not use them for what they have been justified originallynd bypass that justification giving them to allow someone to bypass the current rules of a RIR.


Consider the following fully legitimate justification:
Numbers will be used to identify internet connected hosts on our network and our customers’ networks.

Nothing in that statement specifies the particular manner of connectivity of the customers. There is no basis in policy to reject that justification. Specifics about number of hosts, etc. can be asked, but with customer churn, there must be an expectation that these numbers and the exact nature and topology will change over time.

> If any organization is holding resources which it doesn't justify anymore it either gives it back to AfriNic or transfer to another organization who have usage and justify for that.


Leasing is exactly the same as a transfer, except that it is temporary in nature. It’s a standard LIR assignment like any other still based on needs of the customer. Only difference is that the customer is getting their connectivity services from one provider and their addressing from another.

> IP Leasing is a clear way to show the RIR and Community that resource holder doesn't justify to keep that IP space to anymore.


How is leasing different from any other LIR assignment? As long as the customer in question has need, it’s just an assignment for customer need. If necessary, it’s easy for the leasing company to provide connectivity services in addition to the primary connectivity provided by other providers and then there’s literally no difference. There are a variety of ways those connectivity services could be provided that wouldn’t interfere with primary connectivity through other providers and don’t require significant overhead on the part of the LIR or the customer, so if necessary, that could easily solve the problem even if it were prohibited.


> Fernando


> On 02/07/2021 15:45, Mimi dy wrote:

>> Hi Fernando,


>> I am wondering what basis do you use to define “a wrong option”? And who gave you, or me or the community the right to determine how networks are used? Does the CPM entitle us the right to tell a certain company; “you have the option to use Inter RIR transfer policy”? I may have missed that, but please point out to me where the CPM gives us the right to intervene with others and their networks just because we do not like it.

>> That is just bizarre.


>> Best,


>> Le ven. 2 juil. 2021 à 18:39, Fernando Frediani <fhfrediani at <mailto:fhfrediani at>> a écrit :

>> So they are relying on a wrong option which should never have relied.

>> If they have needs for IPv4 (as everybody else) and they cannot get these addresses directly from the RIR as per the current rules which apply equally to everybody they have the option to use Inter-RIR transfer policy available on all other RIRs.


>> If these organizations are from outside Africa region then it is even worst they grab unused addressed that were assigned to a local company to use somewhere else out of the region.


>> Not everything that is useful or convenient to some is correct and as such should e stimulated and IP leasing mean the current holder doesn't justify for those addresses anymore, so either it gives it back to AfriNic or transfer them definitely.


>> Regards

>> Fernando


>> On 02/07/2021 14:29, Mimi dy wrote:

>>> Hello Fernando,


>>> Many organizations rely on IP Leasing in order to acquire number resources quickly and affordably to meet their current and future needs. It is totally legit, especially during the IPv4 exhaustion phase, where resource scarcity represents a real issue for ISPs and network-holders in AFRINIC's service area.

>>> I find it absurd that you are arguing against IP leasing when it is a legal and accurate way to obtain IPs. Indeed, there are some malicious organizations out there misusing leased IPs, but that is certainly not the case for everyone, so no need to generalize. Consequently, you cannot really dismiss IP leasing using weak arguments as such.


>>> Since IP leasing is very helpful to numerous entities in the period of shortage of available IP addresses, and is certainly legal, I fail to understand why you are advocating against it.



>>> Best,






>>> Le ven. 2 juil. 2021 à 16:48, Fernando Frediani <fhfrediani at <mailto:fhfrediani at>> a écrit :

>>> Well, like it or not but having a customer that is in the leasing

>>> business may effectively change our opinion about some subject, even if

>>> personally you wish it may not to.


>>> Trying to find an exact 'ipsis literis' word in the CPM that fulfill or

>>> not your expectations may not always work. There is always room for some

>>> interpretation and staff is the one responsible to do that in this context.

>>> For the absurd leasing possibility is very simple: if leasing proposes

>>> cannot be used as a justification to receive a new block from the RIR

>>> why would it be after you receive it and missuse it for different

>>> proposes other than bring connectivity to your customers. In that sense

>>> I really hope staff stand strong in revoking resources that are being

>>> used for leasing proposes, different from what they have been justified

>>> originally and if necessary fight in courts of Mauritius to have that

>>> decision preserved.


>>> For out of the region usage there have been multiple people who showed

>>> that is not currently permitted. Maybe you don't agree with that but

>>> bottom line is that is what staff has been interpreting from the current

>>> rules backed by what some of us have put here based in previous messages.


>>> Want to use AfriNic resources in a different region ? Simply transfer

>>> them permanently using the soon-to-come Inter-RIR transfer policy and

>>> bound to the rules of the new RIR.


>>> Regards

>>> Fernando


>>> On 02/07/2021 04:46, Owen DeLong via RPD wrote:

>>> > Full disclosure: I don’t personally have a dog in this fight. I am personally

>>> > agnostic as to whether leasing should or should not be permitted in a

>>> > newly developed policy.

>>> >

>>> > I do have a client that I consult for which is in the leasing business. It is my

>>> > opinion that their leasing business is 100% compliant with policy as it is

>>> > written and that if the community doesn’t like that fact, the community can

>>> > and should certainly amend the policy to rectify the situation.

>>> >

>>> >> On Jun 29, 2021, at 03:08 , Frank Habicht <geier at <mailto:geier at>> wrote:

>>> >>

>>> >> Hi,

>>> >>

>>> >> On 29/06/2021 12:01, Owen DeLong via RPD wrote:

>>> >>> nectivity customers or use out of the region as something "normal and

>>> >>> acceptable".

>>> >>>

>>> >>> Regardless of who does and does not benefit, the reality is that short

>>> >>> of an actual government with the ability to enforce its rules using

>>> >>> guns and prisons, people who can make a profit are going to do what

>>> >>> they are going to do.

>>> >> I need to break this down.

>>> >> I'm working in my $dayjob for one of those companies that are after

>>> >> $profit. What this company _did_ is subscribe to the methods and rules

>>> >> of a Mauritius company called AfriNIC, in order to get Internet

>>> >> Numbering Resources. And I think many of the AfriNIC members formally

>>> >> subscribed to these rules. (And the rules are subject to change

>>> >> according to PDP)

>>> >>

>>> >> These INR are provided to members per need and justification. Relatively

>>> >> recently additional rules came into force that limited each allocation

>>> >> to maximum /22 - this is how rules can change.

>>> >>

>>> >> INR are delegated to members that need them themselves, and AfriNIC

>>> >> calls these members "End-User" members. They are also delegated to

>>> >> members that provide internet access to respective customers, and

>>> >> AfriNIC calls these members "LIR" members.

>>> > You are close, but the term used in the bylaws is “open system protocol

>>> > network services”. I am not sure why such awkward and broad language

>>> > was chosen, but that’s a much broader definition than “internet access”.

>>> >

>>> > In the CPM, LIR is defined as “An IR that receives allocations from an RIR and primarily

>>> > assigns address space to 'end-users’. LIRs are generally ISPs. Their customers are other

>>> > ISPs and possibly end-users. LIRs must be members of AFRINIC.”

>>> >

>>> > Again, there’s not a single word in that definition that ties it to connectivity

>>> > services or internet access.

>>> >

>>> >> I believe in all justifications for IPv4, LIR members request/require

>>> >> the addresses to address customers, or servers, or VMs that get

>>> >> connectivity services from the LIR member. And there is no problem with

>>> >> that. LIR is in the business of making profit, providing connectivity,

>>> >> hosting servers, services, needs IPs, gets IPs.

>>> > Certainly this is the prevalent model, whether or not it is 100% pervasive

>>> > I am not sure.

>>> >

>>> >> There is a big difference to the case where an LIR member

>>> >> - has IPv4 address space,

>>> >> - is not using it themselves,

>>> >> - not for connectivity (or hosting) customers

>>> >> and has the IPv4 space used by "customers" that are only getting the

>>> >> IPv4 space as a service - sold or leased.

>>> > Is there? So long as the customers in question are justifying the space to the

>>> > same standards that an end-user applying to the RIR would have to or to the

>>> > same standard that would be required if they were also getting connectivity

>>> > from the LIR, then what exactly is the difference?

>>> >

>>> > What if the LIR in question did announce the covering aggregates of space

>>> > they leased and provided some minimal connectivity to the customer in question?

>>> > Now they meet the definition you’ve provided above, but they’re not actually

>>> > moving packets because the more-specific being announced to the customer’s

>>> > higher bandwidth providers will win vs. the aggregate.

>>> >

>>> > Does removing this connectivity fig leaf really change the nature of the

>>> > assignment in a meaningful way?

>>> >

>>> >> Is that the purpose for which the IPv4 space was obtained and justified?

>>> > Since I don’t have access to anyone’s IPv4 justifications to AFRINIC in a

>>> > manner which would allow me to comment publicly, I’m going to skip this

>>> > question. Suffice it to say, I can imagine a number of ways in which this

>>> > is possible.

>>> >

>>> >> There are "rules" that say an LIR should notify when use of an IP block

>>> >> changes.

>>> > Yes. The rules are, however, ambiguous at best and it’s not clear at what

>>> > level of detail a “change” is constituted nor is it clear whether an update

>>> > to whois is adequate notification in most circumstances.

>>> >

>>> >> I see a big difference between changes *within an LIR* and changes to

>>> >> *use the IP space outside the AfriNIC member LIR*.

>>> > So if I have space that was allocated to my LIR and I assigned it to

>>> > customer A who is using the space in their network (technically outside

>>> > of my LIR), but then they return the space when they get their own

>>> > block and become a BYOA customer, my assigning that space to customer

>>> > B for their use on their network (also outside my LIR) becomes a problem

>>> > or change in the usage exactly why?

>>> >

>>> >> With the first, I consider it generally accepted that justification remains.

>>> >> With the latter, I believe that the *LIR that subscribed to AfriNIC

>>> >> rules* has shown to no longer have the justification for these IPs for

>>> >> connectivity and hosting, including "PA" customers.

>>> > What if the justification in question was not “connectivity and hosting”?

>>> >

>>> > What if the justification was “Numbering hosts on customer networks”?

>>> >

>>> >> The reason for doing the latter is obviously $profit, and yes - some "

>>> >> are going to do what they are going to do ".

>>> > The reason for the former was obviously profit, too. Nobody is in business

>>> > to subsidize the benefits of others without making a profit.

>>> >

>>> >> And what this community allows them to get away with.

>>> > It’s not so much a question of “get away with” as “what the rules actually

>>> > say” from my perspective. You may wish to argue that the intent or even

>>> > the clear intent of the community is something else, but in reality, for rules to be

>>> > useful, one must consider what the rules actually say, and not the current

>>> > popular interpretation of intent around the rules.

>>> >

>>> > Making it up as we go along has become somewhat of an AFRINIC tradition

>>> > at this point, seemingly both in the staff actions and in the board, PDWG,

>>> > community, and various committees.

>>> >

>>> > There’s also a pretty strong history of doing so being the source of a great

>>> > many problems, so I continue to hope that we can learn from those mistakes

>>> > and start actually following the rules as they are written and making the

>>> > changes necessary through the proper processes when the rules do not

>>> > meet the perceived needs of the current situation.

>>> >

>>> >> To be Frank: I simply don't believe that

>>> >> AS212552 "BitCommand" in Armenia gets IP connectivity services from

>>> >> ... you know who.

>>> > Honestly, I don’t know who, but it’s easy enough to look up:

>>> >

>>> > <>

>>> >

>>> > Says that they get apparent transit from AS64515 and AS24940.

>>> >

>>> > This seems to be borne out by <>

>>> >

>>> >> In other continents / RIRs the IPv4 space is finished. Noone has any

>>> >> hope of justifying any with the RIR. Some have more than they need -

>>> >> give or sell it to others that have "a need" and the market can probably

>>> >> regulate that.

>>> > ARIN is still issuing /24s under NRPM section 4.10, so that’s not entirely

>>> > correct.

>>> >

>>> >> But AfriNIC still has and is distributing IPv4 - should it do so by

>>> >> "whoever pays most" or "everyone according to their need [upto a /22

>>> >> ;-)]". Has it given IPv4 resources to members according to their

>>> >> respective (perceived) needs???

>>> >>

>>> >> Wasn't one of the rules that the LIR was to use the IPs for the

>>> >> connectivity (or hosting) services?

>>> > I’ve reviewed the bylaws, the RSA, and the CPM pretty carefully. I couldn’t

>>> > find a connectivity requirement other than one that calls for the numbers

>>> > to be “routed on the internet” (which, btw, is a unique requirement in

>>> > AFRINIC not present in other RIRs).

>>> >

>>> >> Are the rules still applicable?

>>> > The rules still apply as written, but that’s the real sticking point. Do we

>>> > want to focus on the common perception of what we think the rules

>>> > say (as you have done above) or do we want to review the rules as

>>> > they are written and call for the enforcement of those rules according

>>> > to a plain text interpretation of their actual content?

>>> >

>>> >> bit more below...

>>> >>

>>> >>> I’m not particularly happy about this reality, but I do recognize that

>>> >>> it is, in fact, reality and I’m not in favor of giving RIRs guns or

>>> >>> the ability to incarcerate people. Contracts only get you so far and

>>> >>> clever people can always find ways to comply with the letter of a

>>> >>> contract while circumventing the other party's intent if they want to

>>> >>> try hard enough.

>>> >>>

>>> >>> So no, these are not “nice words”, they are the recognition of

>>> >>> unpleasant and inconvenient truths that like it or not, we are faced

>>> >>> with new realities, economic, technical, and legal.

>>> >> Is one of these realities that an LIR got resources from AfriNIC for

>>> >> providing connectivity (or hosting) services, and now these are no

>>> >> longer in place?

>>> > I have no knowledge of such a situation, but in truth I have not read

>>> > the original justification for the space issued to the LIR I think you

>>> > are referring to.

>>> >

>>> >>> In many countries legal frameworks the lack of a transfer policy

>>> >>> allowing registrants to monetize the transfer of their registrations

>>> >>> could be considered either restraint of trade or an

>>> >>> anti-trust/anti-competitive matter.

>>> >> the fact is that these numbers should be unique and centrally managed.

>>> >> These anti-trust lawyers can send a better proposal for managing them.

>>> > The ability to sell one’s registration to another does not in any way impinge

>>> > the central management of numbers for uniqueness.

>>> >

>>> >> The question is whether "according to need" or "according to whoever

>>> >> offers more $$".

>>> > This assumes that monetized transfers and/or leasing cannot be done

>>> > on the basis of need, which is a false premise. To the best of my knowledge,

>>> > Larus is quite scrupulous and detailed in collecting need justification from

>>> > customers prior to issuing addresses to them. That is certainly the written

>>> > company policy and has been the case with each and every recipient

>>> > case I have been involved with in my consulting for them.

>>> >

>>> >> Should I be allowed to "buy" a /16 from AfriNIC, put it in a safe, sell

>>> >> it 3 years later for $profit ???

>>> > No. The rules prohibit you putting it in a safe and not routing it. Also, you

>>> > aren’t buying the /16, you are paying a fee for the service of recording and

>>> > maintaining the registration of the space. You can’t sell the integers, but

>>> > selling the registration of the integers has become common practice

>>> > worldwide whether you like it or not.

>>> >

>>> >> Is that the purpose for which AfriNIC got the /8's from IANA?

>>> > Things have changed since the IANA was issuing /8s. The world has changed.

>>> > Many of the /8s were issued by the IANA in order to support Email, FTP, and

>>> > NNTP. I suspect there are very few servers running FTP or NNTP these days,

>>> > and while EMAIL is still a pervasive technology (for better or worse), it is not

>>> > a significant fraction of internet traffic.

>>> >

>>> > Very few of the /8s issued by IANA were issued during a time when streaming

>>> > video could have been considered as a purpose for issuing them, yet today

>>> > it is probably the largest consumer of bandwidth on the internet by far.

>>> >

>>> > Should we require all of the RIRs that have issued space to Netflix after

>>> > IANA runout to reclaim and return that space to IANA and rejustify it because

>>> > streaming video was not the purpose for which it was issued?

>>> >

>>> > I think not.

>>> >

>>> >> PS: all or most questions are serious. answers will help.

>>> > All of the answers were serious as well. I’d expect nothing less from

>>> > someone of your stature in the community.

>>> >

>>> > I hope the answers are helpful.

>>> >

>>> > Owen

>>> >

>>> >

>>> > _______________________________________________

>>> > RPD mailing list

>>> > RPD at <mailto:RPD at>

>>> > <>



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