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

Fri Nov 12 16:18:36 UTC 2021

Hi Ibeanusi,

If you’ve no addresses in the AFRINIC pool, and you don’t have a policy that allows transfers with other RIR regions, that are more advanced in the deployment of IPv6 and already have and will have some excess of addresses, you will not be able to access the transfers from those regions.

If you don’t have a reciprocal policy, the transfers with regions that have already more addresses available for transferring (ARIN), aren’t accepted.

Yes, having a reciprocal policy means that some addresses from AFRINIC can go out, but it doesn’t make too much sense if those aren’t longer needed outside and the stats from the recent years show clearly that most of the addresses being transferred come from ARIN towards the other RIRs. This is just real facts.

In addition to that, I believe the policy proposal has sufficient provisions to avoid abuse. If you think I’m missing something, please let’s know and I will be happy to elaborate on that.

Regards,

Jordi

@jordipalet

El 12/11/21 16:54, "Ibeanusi Elvis" <ibeanusielvis at gmail.com> escribió:

Dear all, 

This policy “IPv4 Inter-RIR Resource Transfers (Comprehensive Scope) Draft-7” although has been in debate for the past few years and PPM’s. Amongst the summary of the problems being addressed by this proposal is the “new businesses can’t be established in the region, due to lack of addresses” and hopes on addressing the problem from this current modified version of the proposal by “enabling bidirectional, compatible and reciprocal transfers with all the other RIRs” 

Won’t this result in the greater loss of IPv4 in the African market which is already in it shortage as to encouraging the development and creation of businesses.

On Fri, Nov 12, 2021 at 17:44 JORDI PALET MARTINEZ via RPD <rpd at afrinic.net> wrote:

Hi Owen, all,

As you know, most of us aren’t native English speakers, so it is easy that we can make mistakes. However, those mistakes can be corrected, as we did in previous proposals, at the PPM, or even during the last-call if they reach consensus. So, if we all agree on your suggestions regarding 5.7, I will’ve no problem on that. Could the staff, before the PPM, tell us if this alternative wording still has for them the same interpretation, and consequently it is a clear editorial change?

Regarding 5.7.1, in our previous discussion (https://lists.afrinic.net/pipermail/rpd/2021/013837.html), we already agreed that this paragraph is not needed, but it was requested by the staff to make it clearer. In other RIRs there is nothing like that text. It doesn’t harm to have it. Today, M&A is an internal procedure. If tomorrow the community decides that it must be a policy, then we just need to include in that policy proposal the removal of that text. In fact, once we resolve the transfers, I plan to resubmit my proposal for M&A.

Regarding 5.7.2.2/3, the 16 months are considered using an existing timing in the CPM section 5.4.5, times 2. I think it is a very simple way to agree on that, otherwise, each community member will have a different view and we will not be able to reach consensus. I don’t think it is so important and if the community believes that it need to be amended, we could make it after the proposal reach consensus, considering that the implementation of such policy will typically take 1 year and the timing is not critical for the implementation time (is just a parameter in the scripts).

Regarding 5.7.4, most of the text on this section is more an example that anything else, because the other 4 RIRs already have a cooperation system to exchange this information and make it public, so as said in the policy text “This doesn’t exclude the publication of the same or other information as a result of the operating agreement among the RIRs.”.

Regarding 5.7.5, the text has been amended as we discussed in the previous round and with the inputs from the staff. I’m not going to discuss with you “personal views” (which I also have my owns and not necessarily in favor of recent Board actions) vs this proposal text. If we believe that things are broken, we shall address that in other places, not in every single proposal, because *anything* in the PCM can be used as weapon against the members and community, if the staff/board decides so, and this is consequently not a problem for any specific policy text, it is a wider organization issue. If you remove 5.7.5, following the RSA, the staff still can do *exactly the same* and even more, and can *deny* the transfers and reclaim the resources because the justification of the need is no longer there. As such, this will be even more against the members and the community than keeping 5.7.5.

Regarding 5.7.6, I agree with you, but the staff is suggesting that it adds clarity as I just explained in my previous email. I don’t think it harms so I will say let’s keep it.

Regards,

Jordi

@jordipalet

El 10/11/21 18:51, "Owen DeLong via RPD" <rpd at afrinic.net> escribió:

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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