[rpd] IPv4 Inter-RIR Resource Transfers (Comprehensive Scope) - AFPUB-2019-IPv4-002-DRAFT07

[Owen DeLong]

This version has the following problems;

Proposal:
5.7 This policy applies to any entity with a justified need for IPv4 resources (recipients) and entities with IPv4 resources which no longer need (sources).
The resources to be transferred must be from an existing Resource Holder (including Legacy Resource Holders) in the AFRINIC service region/other RIRs.

Correction:
5.7 This policy applies to any entity with a justified need for IPv4 resources (recipient) and any entity with IPv4 resources which are no longer needed (source).

The resources to be transferred must be from an existing Resource Holder (including Legacy Resource Holders). At least one of the parties (source or recipient) must be an AFRINIC resource holder or be eligible to become an AFRINIC resource holder as a result of the transfer (per 5.7.3.1, et. al.).

Reasoning:
First, the syntax of the first sentence was awkward and had an invalid mix of singular and plural. Grammatical and syntax correction, but original meaning preserved.

Second, the sentence was awkwardly worded and did not achieve what I believe to be the author’s true intent.

Proposal 5.7.1 …M&A not covered…

Correction:
instead of simply stating that M&A transactions are not covered by the policy, reference should be made to the policy under which they are covered. If there is no such policy, then the exception should be removed from this policy.

Reasoning:
M&A transactions occur, both inter and intra-RIR. That is simply the current reality. Prohibiting them from being recognized puts policy out of step with reality and guarantees inaccurate registration information.

Proposal 5.7.2.2 …Not less than 16 months…

16 months seems a very arbitrary period of time (1 1/3 years). Suggest that this should be modified to 12, 18, or 24 months. Suggest a similar change to 5.7.2.3 as well.
Personally, I would favor 24 months, with 18 as my second choice.

Proposal 5.7.4: Suggest adding the following to the required information list:
	Source ORG-ID
	Recipient ORG-ID

I continue to object to 5.7.5. In the situation with an ethical RIR, I agree this provision would not be a problem. However, with the current crew of shake down artists in control of the AFRINIC management and board where we have seen made up interpretations of the bylaws and the CPM used in an effort to extort money from members, this provision is perfectly positioned to be weaponized in order to deny legitimate resource holders the ability to protect their rights.

Proposal Section 5.7.6 is non-operative and has no effect. Therefore, it should be stricken IMHO.

Owen

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