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[rpd] IPv4 Inter-RIR Resource Transfers (Comprehensive Scope) Policy Proposal: Impact Assessment & Summary of Objections

Fri Nov 12 16:53:04 UTC 2021

(some typos corrected and added one more point)


Hi Chairs, all,


I’m responding to this email considering the version 7 of the proposal (AFPUB-2019-IPv4-002-DRAFT07), which was edited precisely to respond to the issues from the impact analysis and inputs from the list. Actually, my response and new version had an additional delay, because the IA published was from another proposal, so I couldn’t read the IA when I was expecting to do it.


By the way, those emails from the chairs are very useful, however, it will be more useful if either plain text or html is used, so then we can respond in-line to each of the points. They are images, which make that impossible.

Regarding the absence of the “hold down”. I was not convinced myself it that’s needed and I double-checked what other RIRs equivalent policies have on that. The only one that has this is LACNIC, and unfortunately I don’t recall the discussion (if any) for the need for that. However, I’ve asked the AFRINIC staff for examples about why this may be required and how the abuse may be produced, and I didn’t got any response on that. My rationale is that if there are some resources transferred, and then after weeks or months, the justification for the need disappear (for example, business model change, or they have deployed IPv6 and they need less IPv4 resources), why not those resources can be transferred again? In fact, this is good for the community because instead of someone having resources that aren’t being used, someone else could make use of them. So, in summary, this observation from the IA is not justified and can’t be considered as a valid objection.

Chairs shall notice that even if the impact analysis is extremely useful to authors and community, the staff can have a totally different view from the community, so the impact analysis is good as a point for discussion but never can be considered “per se” as objections unless duly justified.

Regarding the AFRINIC role, while this is not considered in any other RIR, because in my opinion is something very obvious (the role of the RIR is just helping, and the final responsibility is on the source and recipient of the transfers), I understand that having some text that clarify that is not harming, so I’ve added section 5.7.6 (Due diligence) in the new version of the proposal to address it.
Regarding the RSA signature, again, while I believe this is obvious and once more is not explicit in other RIRs, I’ve added text to clarify it. Note that there is no such 3.6 in the proposal, so I believe there is some mismatch in your text, may be chairs also reading the wrong IA? So, in summary, section of the proposal, already was clear, but now has been edited to be even more explicit on this in
Section 5.7.5 has been updated to be clearer and now explicitly allows that other violations of the RSA/CPM aren’t “protected” by the pre-check.
Regarding the financial impact, *all* the policy proposals for transfers which are reciprocal *may* have an impact if the transfers are outgoing, which the stats from all the years that transfers among other RIRs demonstrated that is not the case, because the major “donor” is ARIN towards other regions. Besides that, if an existing LIR is transferring resources outside the region is because a) The LIR is not anymore offering services or, b) The LIR already deployed IPv6 and in that case, they will be paying the fees for IPv6. Note that the waiver for IPv6 fees is only for members with IPv4 allocations (if all the IPv4 addresses are transferred, then IPv6 fees will apply). Further to that, in an extreme case were *too many* transfers are being done from AFRINIC to other RIRs and not incoming transfers, the Board can use bylaws section 11.4 to freeze the transfers and expose the problem to the community. So such financial (negative) impact is not feasible and should be balanced, as the IA indicated as well, with the incoming transfers (IA section 3.7.2).
There is an additional point in this version of the proposal that I noticed while doing other edits. I’ve amended across all the text “organization” with “entity” because organization is the wrong term and it will be discriminatory. If we use “organization”, it may be understood (in laws terms) as only legally constituted organizations (in law terminology “juridical person”). If an “individual” has resources (even legacy), under its own “personal” (“natural person” in law terminology), “organization” will NOT allow the transfers in that case. In other RIRs the terminology/wording being used doesn’t create this problem. So, using “entity”, doesn’t create this problem or any other problems. I’ve asked the staff about that and at the moment got no response.
Finally, in my understanding the changes applied to this version of the proposal doesn’t change the already confirmed reciprocity status vs. other RIRs (reciprocal with all the other RIRs), as it is not imposing any condition that after the other RIRs.

I believe I’ve resolved the issues from the previous version IA, so even if I understand that time is too short, it will be good if the staff can do a quick check *before* the PPM, in case we have further questions to clarify, so we avoid unnecessary discussions/waste of time in the PPM.


I will like to add something, valid for all the proposals. Even if the IAs are coming extremely late and that makes very difficult to authors to react and provide new versions with sufficient anticipation to the PPM, I want to congratulate the staff because the way they are cooperating with authors is very efficient and I believe fruitful towards facilitating the discovery of possible issues. I’m not saying that I agree in all their points, but at least, they make you consider all the possible issues and how better organize the proposal text to facilitate the community understanding of the proposal.










El 4/11/21 17:03, "PDWG Chair" <vincent at> escribió:


Dear PDWG,


We are pleased to announce that:-

a.    The impact assessment of the proposal IPv4 Inter-RIR Resource Transfers (Comprehensive Scope), ID: AFPUB-2019-IPv4-002-DRAFT06 has been published at



d.    The summary of the concerns/objections on this proposal is as follows:-

We request the authors to consider the pending concerns/objections and that an update of their proposal can be submitted until 10 November 2021 at 23h59.


We encourage the PDWG to discuss the merits of the proposal by keeping this discussion thread using the following guidelines :-

a.    Do you agree with the problem statement and proposal as written?

b.    Have you encountered an issue similar to the problem statement in the proposal?

c.    Do you have any objections to the proposal as written. If yes, please state the sections and document your objections.

d.    Are there any areas in the proposal that are ambiguous? If yes, please provide the changes you would like to propose.



Vincent Ngundi & Darwin Da Costa


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