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[rpd] IPv4 Inter-RIR Resource Transfers (Comprehensive Scope) - AFPUB-2019-IPv4-002-DRAFT07
JORDI PALET MARTINEZ
jordi.palet at consulintel.es
Sun Nov 14 08:38:06 UTC 2021
Hi Owen, all,
(subject replaced for the right proposal)
Below, in-line as [Jordi].
El 12/11/21 19:32, "Owen DeLong" <owen at delong.com> escribió:
On Nov 12, 2021, at 00:21 , JORDI PALET MARTINEZ via RPD <rpd at afrinic.net> wrote:
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. The are images, which make that impossible.
1. 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 unfortunatelly 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 dissapear (for example, bussiness 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.
The bigger concern is speculators who might be buying resources just to flip them for profit, much like speculative real estate buyers which have been a rather persistent problem in the US housing market.
[Jordi] I believe that the actual text of the proposal already protects against that. Corner cases, yes they may happen but if someone want to fake the system they will always find a way to do so and as more we add conditions I don’t think we will be able to escape 100% from that.
Another concern is so long as the free pool persists, there is a concern about artificial justifications for low-cost resources being obtained and then rapidly turn around and sell them for profit.
[Jordi] This is already prevented by:
“184.108.40.206 An entity that has received IPv4 resources from AFRINIC within the preceding 16 months will not be approved as a transfer source.”
Also, if you obtain resources from AFRINIC with the only goal to transfer them to make profit and consequently your justification for the need is artificial, the transfer pre-check at 5.7.5 will discover that and you will not be only not able to transfer but also the resources may become recovered.
Finally, there is the concern of selling resources for profit and then turning around and back filling the need from the free pool.
[Jordi] This is prevented by:
“220.127.116.11 Source entities will not be eligible to receive any further IPv4 address allocations or assignments from AFRINIC. Source entities may, if they can show justified need, receive resources via transfer after a period of not less than 16 months (twice the window defined by 5.4.5) has elapsed from their last outbound transfer.”
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 justitified
Here, I mostly agree, but with greater constraints. The impact analysis should be limited in scope to those impacts which the staff sees as a predictable impact to the RIR from the proposed policy. It shouldn’t go into speculation or ideology. It should stick to the facts and be a neutral report of the reasonably predictable results of implementing the policy and document how staff would interpret the policy as written and how it would be implemented.
It should not be considered an objection unless there is a legal or fiduciary concern expressed and any such concern should be clearly called out as such and its basis should be well documented.
[Jordi] I mostly agree here with you. However, if there is a persistent problem in all the impact analysis, as it is happening, because a “legal” friction between the community right (which are always on top of any RIR) and the RIR/membership itself, then it shows a clear problem with the bylaws and/or RSA that must be corrected. The only RIR which the bylaws are generating such kind of interferences is AFRINIC: that should tell us something! In fact, if we strictly follow the bylaws, many of the most active participants in the PDP will not be able to participate, because the definition of (17) “Internet community” in the bylaws restrict that to “any person or corporate body living or operating in the AFRINIC service region” and then the PDP definition (23) calls for that “Internet community” definition. Also 11.3 talks about “Regional”. There many other problems, those are just examples. Somebody was not really doing a good job at all when the bylaws where written and even worst, they should have not passed the ICP-2 approval!
2. 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 digilence) in the new version of the proposal to address it.
5.7.6 is utterly unnecessary. It has nothing to do with number resource policy and should be stricken.
AFRINIC is a registry. They keep track of who is the registrant of a set of number resources within a cooperating set of entities (the RIR system and those ISPs who choose to implement their networks in accordance with the RIR system). They are there to guarantee uniqueness among those cooperating entities, manage the registrations within that database according to policies set by the community, and provide a forum for the community to develop said policies.
They are not a governing body. They are not a regulator. They are not kings of the internet, gods, or even a court of arbitration. They are just an NGO with a mission. That mission is to provide unique registrations of internet number resources according to community developed policies and facilitate the use of those registrations among cooperating entities who choose to work within the system.
Recent attempts to weaponize AFRINIC are proof that some, including many among AFRINIC leadership have either lost sight of this or have an alternate agenda seeking to enrich themselves. I honestly don’t know which is the case at this point, but it is clear that there are problems which need to be addressed.
[Jordi] 5.7.6 has been added under request form the IA. As said I agree it is not needed, because it is obvious, however it doesn’t harm if it avoids objections based on the IA text on this.
3. 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 18.104.22.168 of the proposal, already was clear, but now has been eddited to be even more exlicit on this in 22.214.171.124.
I think you mean edited and explicit.
[Jordi] Yes, I’ve resend this text in a subsequent email (and added a point that I missed) because I was using a previous email from a previous proposal … I believe I corrected those typos as well in my subsequent email.
4. Section 5.7.5 has been updated to be more clear and now explicitly allows that other violations of the RSA/CPM aren’t “protected” by the pre-check.
Section 5.7.5 is getting worse instead of better. This entire pre-check provision is an opportunity to weaponize AFRINIC to hold resources captive in the case that some staff member or leadership person dislikes a transfer source for whatever reason. It provides broad latitude to inflict arbitrary judgment.
Given recent weaponization of AFRINIC processes against certain members, I must strenuously object to any policy proposal that contains this provision.
[Jordi] As said, even if we don’t have this text explicit, AFRINIC can and shall do exactly the same. This text actually protects the resource holders from being reclaimed for the resources in case of a failed transfer, because the lack of need will come on the back of the resource holder in that case: “I don’t need any more the resources, but I’m transferring them – oh because the transfer failed – the recipient is not fulfilling the requirements – now I can “artificially” justify again the need otherwise I need to return the resources of face a reclamation”.
5. 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.
The term should probably be “registrant”. Alternatively, “ORG-ID” would be fine since that would clearly represent an entity in the database represented by an ORG-ID.
[Jordi] I’m fine with that, either way is good. As it doesn’t change intent of the text, we can fix it at any time if the community or staff prefers one term or another.
6. Finally, in my understanding the changes apllied to this version of the proposal doesn’t change the already confirmed recipocity status vs. other RIRs (reciprocal with all the other RIRs), as it is not impossing any condition that affer the other RIRs.
I believe the current version would still be considered reciprocal by the RIRs where that matters.
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