[rpd] New version of policy Proposal - IPv4 Inter-RIR Resource Transfers.

Sun Oct 10 21:23:47 UTC 2021

Tks Owen,

I will wait a week or so for further inputs before publishing the new version.

Can also the staff indicate if they see any issue with those changes. I know they will do with the analysis impact, but a pre-IA could avoid having multiple versions before the next PPM or even having any big issue in the PPM itself if the IA is not published at least 2 weeks before then.

Regards,

Jordi

@jordipalet

El 10/10/21 22:05, "Owen DeLong" <owen at delong.com> escribió:

Works for me. I now support.

Owen

On Oct 10, 2021, at 00:39 , JORDI PALET MARTINEZ via RPD <rpd at afrinic.net> wrote:

Hi Owen,

So, 5.7:

The resources to be transferred must be from an existing Resource Holder (including Legacy Resource Holders) in the AFRINIC service region/other RIRs.

·         Note that the explicit mention to legacy resource holders is to avoid questioning about that in the impact analysis, or objections during the discussion because it is not sufficiently clear. Anyway, if the staff believes that this mention is not needed, I’m happy to remove it.

5.7.1. I agree that it shouldn’t be an internal procedure but a policy. I proposed a policy about that, same as I did in other regions. In the case of AFRINIC it was not supported 2-3 years ago. I think is something to tackle once we have sorted out the transfers. Trying to do it at once, will create more obstacles for a possible consensus.

5.7.5.  I’m fine with your proposal:

“All the transfers where the source is an AFRINIC resource member will be required to pass a pre-check in order to verify that the resources being transferred were allocated/assigned and used in accordance with the requirements in section 5.7.2.1”.

è However, note that this doesn’t precludes AFRINIC doing other checks never mind you consider them as part of the pre-check or not. They can, as it is their obligation, review if the resources holders are following the RSA and CPM *at any time*. My wish to include “RSA” in that sentence is to make sure that anyone reading the policy is transparently aware of that. Note also that what you see as possible RSA violation is precisely what I’m avoiding with the possible transfer failure in the next paragraph:

“It can happen that a transfer fails due to the recipient failing to be compliant because the lack of proper documentation or non-compliance of the relevant rules, while the source passed the transfer pre-check. This proposal allows the successful transfer pre-check to be valid for up to 12 months after the failed transfer; i.e AFRINIC will not initiate a recovery/reclamation process in this period.”

So, it is clear that the act of making the resources available for transfer can NOT be construed as a violation of the usage requirements.

Of course, if you declare “I don’t need any more those resources, so I’m transferring them”, the transfer fails because the recipient can’t demonstrate the need, then you either actively search for another valid recipient or your network grows so you don’t need any more to transfer the resources and you are NOT violating the RSA/CPM.

Is that clear or there is something broken in my rationale that I’m missing?

El 10/10/21 0:26, "Owen DeLong" <owen at delong.com> escribió:

On Oct 9, 2021, at 02:10 , JORDI PALET MARTINEZ via RPD <rpd at afrinic.net> wrote:

Hi Owen,

Below in-line.

Regards,

Jordi

@jordipalet

El 8/10/21 22:51, "Owen DeLong" <owen at delong.com> escribió:

On Oct 8, 2021, at 1:07 PM, JORDI PALET MARTINEZ via RPD <rpd at afrinic.net> wrote:

Hi Owen,

The modification of 5.7 was done to add clarity to the text. I don’t understand where you see the problem, if there was no problem about reciprocity in the previous versions.

This is the new text:

The resources to be transferred must be from an existing RIR member’s account or from a Legacy Resource Holder in the AFRINIC service region/other RIRs.

There are lots of resource holders in other RIRs (at least in ARIN) who are not RIR members.

The current wording precludes those resource holders from participating in said transfers.

It clearly says AFRINIC/other RIRs, so what I’m missing?

That not all RIRs require membership to have resources. IIRC, this is the case with sponsored PI in RIPE as well.

[Jordi] I should have noticed that, as I was the author of the IPv6 PI in RIPE, which resulted in the “sponsored PI”. So, we have two choices here:

1.      Maybe this text is redundant. I don’t see an equivalent text in other RIRs, and trying to clarify was worse than not having it. Can the staff confirm if they really need this text or it has no impact to remove it, as it was in the previous versions? I don’t recall previous analysis impact requiring a clarification on that. In fact, these conditions are already somehow expressed with the text in 5.7.1.b) and 5.7.2.1. May be the only “excluded case” is if a legacy holder has no registration of the resources in none of the RIRs – is that happening or actually possible?

2.      Use the text that you proposed. In principle I’m fine with that. I will like to see inputs from others, and specially from the staff. We need to make sure that they don’t have any misunderstanding/issue with that. I know they will check with the analysis impact, but it should be possible to have a preliminary view on that?

Why not just refer to “resource holders” instead of “members”

Regarding 5.7.1, the M&A today is not a policy, but an internal procedure (as it happens in RIPE, for example). I don’t agree this should be an internal procedure, but that’s what we have today. My plan is to, once we have fixed this, make a proposal for that, but I think it is better to go step by step, so adding a reference will be breaking it in the future (or requiring one more change in this part of the text). It is not needed. If you look at the existing text for intra-RIR that it is in the policy manual today, there is no such reference.

OK… Ugly, but ok.

[Jordi] I don’t think it is ugly, there are other similar situations in the CPM. We could also just remove that text, as it was in previous versions. I think it is fine keeping it, may be as a foot note and not “policy text” (such as “note Mergers and Acquisitions (inter or intra) are not covered by this policy”. The idea was to ensure that the analysis impact doesn’t “complain” about that. Will be that fine for the staff?

There are many defects in the CPM. I consider them ugly.

I was referring to the situation, not the text.

5.7.5 is to make explicit something that was already there. When you attempt an intra-RIR transfer, *all* the parties are verified. This is the same in other RIRs. However, I’m also adding a “protection” to the failed transfers, because today, if AFRINIC strictly follows the intra-RIR transfer and it fails because, for example, the destination doesn’t meet the policies, then the source will lose the resources, as he clearly demonstrated that doesn't need them and that’s the reason, he is willing to transfer.

What your text for 5.7.5 is proposing seems to be a restriction of some of the RSA and CPM text. I don’t think that’s right, otherwise, each proposal or part of the CPM can actually “change” what is already written in the RSA and/or CPM and create a mess.

I am proposing not allowing staff to block a transfer because they decide they don’t like a registrant.

I am not proposing limitations on other sections of the CPM, but limitations on the excuses staff can use to block a transfer to the criteria that can be measured objectively and without subjecting transfer participants (receive or supply) to arbitrary and capricious misinterpretations of the CPM by a staff which has shown a clear propensity to engage in same.

I’m happy to accept suggestions from anyone, as usual, but they should be reasonable and consistent.

I believe that my suggestions were both reasonable and consistent, with the exception of the 5.7.1 as noted.

[Jordi] I feel that you’re being too much suspicious about the staff and I understand the situation. However, we should not over-micro-manage. In my opinion the pre-check must be done based on the RSA mainly. If there is a problem with the RSA, let’s fix it there. Have you noticed that what you’re asking is already in 5.7.2? Do you think anything is missed there? Would you be ok if we just do something like:

Actual:

“All the transfers where the source is an AFRINIC resource member, will be required to pass a pre-check in order verify that the resources being transferred were allocated/assigned and used following the RSA/CPM provisions.”

Proposed:

“All the transfers where the source is an AFRINIC resource member, will be required to pass a pre-check in order verify that the resources being transferred were allocated/assigned and used following the RSA provisions and 5.7.2.1.”

If we could make that slightly stronger, then yes…

Altenrate proposal:

“All the transfers where the source is an AFRINIC resource member will be required to pass a pre-check in order to verify that the resources being transferred were allocated/assigned and used in accordance with the requirements in section 5.7.2.1”.

Otherwise, the mere act of making the resources available for transfer can be construed as a violation of the usage requirements as currently written in the RSA. I think 5.7.2.1 is perfectly fine and adequately comprehensive if the pre-check scope is limited accordingly.

Owen

**********************************************
IPv4 is over
Are you ready for the new Internet ?
http://www.theipv6company.com
The IPv6 Company

This electronic message contains information which may be privileged or confidential. The information is intended to be for the exclusive use of the individual(s) named above and further non-explicilty authorized disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited and will be considered a criminal offense. If you are not the intended recipient be aware that any disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited, will be considered a criminal offense, so you must reply to the original sender to inform about this communication and delete it.

_______________________________________________
RPD mailing list
RPD at afrinic.net
https://lists.afrinic.net/mailman/listinfo/rpd

**********************************************
IPv4 is over
Are you ready for the new Internet ?
http://www.theipv6company.com
The IPv6 Company

This electronic message contains information which may be privileged or confidential. The information is intended to be for the exclusive use of the individual(s) named above and further non-explicilty authorized disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited and will be considered a criminal offense. If you are not the intended recipient be aware that any disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited, will be considered a criminal offense, so you must reply to the original sender to inform about this communication and delete it.

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.afrinic.net/pipermail/rpd/attachments/20211010/bec2a40d/attachment-0001.html>