I think this policy proposal will not be beneficial in enhancing cooperation with other RIRs. The policy focuses on an inward transfer strategy that is not fully bidirectional and focuses more on an inward transfer as I see no rules regulating inward transfer. The big question is will the conditions be reciprocal from other RIRs and will entities in other RIRs willing to do business with conditions not a little bit beneficial to them as well?. The policy does not seems to benefits a new businesses as new business may not be able to have attained all the criteria stated in the policy for a transfer to be initiated. However I do support intra transfer of ASNs as it has long been overdue.<br><br>On Friday, August 30, 2019, Fernando Frediani <<a href="mailto:fhfrediani@gmail.com">fhfrediani@gmail.com</a>> wrote:<br><blockquote class="gmail_quote" style="margin:0 0 0 .8ex;border-left:1px #ccc solid;padding-left:1ex">
<div text="#000000" bgcolor="#FFFFFF">
<p>Hello Alain</p>
<p>Let me contribute to this from my perspective.</p>
<p>- It was not clear to me if this proposal should start only when
AfriNIC enters Phase 2 or after that, when the IPv4 pool is fully
exhausted. Perhaps that should be explicit in the text.<br>
- If it's during Phase 2 organizations can still receive blocks
and use them also for IPv6 Transition, just smaller blocks up to a
/22 every a couple of months.<br>
- After Phase 2 is finished there is still a /12 Revered for
Future Use and in my view should be used exclusively for New
Entrants or for IPv6 Transition Mechanisms with proper
justification. For that a new policy will have to be presented at
the time with these specific terms. These type of policies already
exist and seems to work well on other RIRs around the world and is
fair with new members in order to give then the bare minimal they
can work from the very beginning.<br>
- With that in place there will not be organizations with "no
resources". For a while it will still be possible for a new
African organizations to receive some IPv4 space, even small and
limited but they will be able to have some directly from the RIR
at least.<br>
</p>
<p>- I think limiting that only Legacy resources and resources
previously transferred from other regions will be transferable out
of the AFRINIC service region won't meet the reciprocity necessary
from other RIRs in order it can happen. As I mentioned in another
message I welcome a Inter-RIR bidirectional Transfer, but only
after AfriNIC enters in Phase 2 which when we will have enough
elements to evaluate the new scenario.<br>
- It mentions "AFRINIC has expressly and in writing approved" -
What does that mean exactly ? Paperwork and an actual firm or just
an email ? I trust AfriNIC as any other RIR will always make
prudent decisions with regards these topics, but we, as
policymakers have to give them the key points they must observe in
order to be able to approve these transfers.</p>
<p>- This is in my view one of the most important points to make it
very clear: Under the "Conditions on the recipient" must justify
the usage of the resource being received. I believe that is
covered under "demonstrate a detailed plan for the use of the
transferred resources".</p>
<p>Best regards<br>
Fernando<br>
</p>
<div>On 30/08/2019 09:55, Anthony Ubah
wrote:<br>
</div>
<blockquote type="cite">
<div dir="ltr">
<div dir="ltr">
<div>
<div dir="ltr" data-smartmail="gmail_signature">
<div dir="ltr">
<div dir="ltr">
<div dir="ltr">
<div dir="ltr">
<div>
<div dir="ltr">
<div dir="ltr">
<div dir="ltr">
<div dir="ltr">Hello Alain Aina and Co.,<br>
<br>
In addition to my previous concerns, I
find that with this new Resources
transfer policy proposal, Business, Eg.
Internet Service providers and other
service providers (Example businesses
offer as-a-Service products like IaaS
and PaaS, also FTTH/FTTP, etc.) would be
restricted from assigning IP addresses
to customers without permission from
AfriNIC.</div>
<div dir="ltr">
<p style="line-height:19.5px"><br>
Thus I suggest a full resource
transfer policy is needed for
effective resource exchange.<br>
</p>
</div>
</div>
</div>
</div>
</div>
<div dir="ltr"><br>
</div>
Kind regards,</div>
<div dir="ltr"><br>
</div>
<div>Anthony</div>
<p style="line-height:150%"><br>
</p>
<div class="gmail_quote">
<div dir="ltr" class="gmail_attr">On Fri, Aug 30,
2019 at 1:47 AM Anthony Ubah <<a href="mailto:ubah.tonyiyke@gmail.com" target="_blank">ubah.tonyiyke@gmail.com</a>>
wrote:<br>
</div>
<blockquote class="gmail_quote" style="margin:0px 0px 0px 0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex">
<div dir="ltr">Hello Alain Aina and Co.,<br>
<br>
<div>There certainly is a need for a full
resource transfer policy to attempt fixing
some of the lapses in the current Intra-RIR
transfer policy.<br>
Thus this is a very interesting proposal, a
good one to say the least.<br>
<br>
</div>
<div>I need a little clarity on some a little
details;<br>
<br>
<br>
Section 2:<br>
Excerpt;<br>
<b>“The goal of this transfer policy is to
help distribute resources from those who
no longer need them to organizations that
need the resources, but cannot obtain them
from the AFRINIC free pools.”<br>
</b><br>
Redistribution of resources in not remotely
a responsibility of AfRINIC. I suggest you
consider reviewing this statement. I feel
the new policy will create an avenue for
resources to be transferred organically in a
transparent system.<br>
<br>
<br>
Section 3.6:<br>
The section describes the Conditions on the
recipient of “resources”<br>
Excerpts;<br>
<b> “…..<br>
- Recipient that does not have prior
resources must:<br>
++ demonstrate a detailed plan for the
use of the transferred resources<br>
(in the case of ASN, recipient must meet
the criteria for assignment of ASN).<br>
- Recipient with prior resources must:<br>
++ demonstrate a detailed plan for the use
of the transferred resources<br>
(in the case of ASN, recipient must meet
the criteria for assignment of ASN).<br>
++ Show past usage rate.<br>
++ Provide evidence of compliance with
AFRINIC policies with respect to past
allocations/assignments.<br>
…..”<br>
<br>
</b>As widely quoted, AfRINIC IPv4 pool is
expected to run out soon, unfortunately, I
feel the above conditions creates a limiting
factor and thus does not necessarily
encourage massive resource inflow into the
region as the region would hope for.<br>
<br>
My concerns include;<br>
<br>
1. A new business with no existing
regional resources might have difficulty or
be forbidden from transferring resource into
the region.<br>
<br>
2. How can one satisfactorily
demonstrate a detailed plan for the use of
the transferred resources? Will business
projections suffice?<br>
<br>
3. Will past usage rate of a resource
owner in another region suffice?</div>
<div><br>
</div>
<div><br>
</div>
<div><br>
</div>
<div>Thanks for the good work put in, in this
proposal.</div>
<div><br>
</div>
<div>Kind Regards,</div>
<div><br>
</div>
<div>Anthony<br>
</div>
</div>
</blockquote>
</div>
</div>
</div>
</div>
</div>
</div>
</div>
<br>
<div class="gmail_quote">
<div dir="ltr" class="gmail_attr">On Thu, Aug 29, 2019 at 1:00
PM <<a href="mailto:rpd-request@afrinic.net" target="_blank">rpd-request@afrinic.net</a>>
wrote:<br>
</div>
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<br>
Today's Topics:<br>
<br>
1. Resources transfer policy Proposal (ALAIN AINA)<br>
<br>
<br>
------------------------------<wbr>------------------------------<wbr>----------<br>
<br>
Message: 1<br>
Date: Thu, 29 Aug 2019 11:36:28 +0000<br>
From: ALAIN AINA <<a href="mailto:aalain@trstech.net" target="_blank">aalain@trstech.net</a>><br>
To: <a href="mailto:rpd@afrinic.net" target="_blank">rpd@afrinic.net</a><br>
Subject: [rpd] Resources transfer policy Proposal<br>
Message-ID: <<a href="mailto:74B25009-9B77-4793-9446-BB7E94CE6760@trstech.net" target="_blank">74B25009-9B77-4793-9446-<wbr>BB7E94CE6760@trstech.net</a>><br>
Content-Type: text/plain; charset=utf-8<br>
<br>
Dear community <br>
<br>
A new policy proposal named "AFRINIC resources transfer
policy" is submitted for discussions. This proposal
obsoletes the current IPv4 transfer within AFRINIC
service region policy, defines rules for transfers of
IPv4 and ASNs within the region and between AFRINIC
service region and other regions.<br>
<br>
The policy allows a category of resources to be transferred
out of the region, another category of resources to be
transferred inside and denies the transfer of certain
resources.<br>
<br>
We expect this to be a response to a harmonised policy which
addresses some of the limitations of the intra-rir policy
and proposes a solution for an inter-rir transfer which
minimizes the foreseen risks of uncontrolled outflow of
resources. <br>
<br>
The co-authors<br>
<br>
<br>
=====================begin====<wbr>=============<br>
Draft Policy Name: AFRINIC Number resources transfer policy<br>
ID: (Assigned by AFRINIC)<br>
Submission Date: 29 August 2019<br>
Version: 1.0<br>
Author(s): (a) Name, (b) Email address, (c) Affiliation, if
applicable<br>
Gregoire Olaotan Ehoumi, <a href="mailto:gregoire@ehoumi.net" target="_blank">gregoire@ehoumi.net</a>,
independent <br>
Mukhangou Noah Maina, <a href="mailto:noah.maina@seacom.com" target="_blank">noah.maina@seacom.com</a>, SEACOM<br>
Komi Elitcha, <a href="mailto:kelitcha@djesido.africa" target="_blank">kelitcha@djesido.africa</a>, Independent <br>
Adeola A. P. Aina, <a href="mailto:alain.aina@wacren.net" target="_blank">alain.aina@wacren.net</a>, WACREN<br>
<br>
Sections of Policy Manual affected <br>
<br>
Obsoletes: IPv4 Resources transfer within the AFRINIC Region
(Section 5.7 of the CPM)<br>
<br>
1. Summary of the problem being addressed by this
proposal<br>
<br>
AFRINIC IPv4 pool is expected to run out soon. Some entities
may need IPv4 space to support their IPv6 deployments,
especially to support transition mechanisms, which AFRINIC
may not meet. The current Intra-RIR policy in force at
AFRINIC allows entities to receive unused IPv4 address from
other members solely within the AFRINIC region, based on
justified needs. Considering the limited IPv4 space
initially made available to AFRINIC (AFRINIC managing only
7.23 /8 with a very low ratio of IPv4 addresses per Internet
users), there will therefore be a need to allow for unused
IPv4 from other regions to move into AFRINIC service region
? this without necessarily depleting AFRINIC's slim amount
of IPv4 addresses by transferring space out of the region.<br>
<br>
The current Intra-RIR transfer policy allows all types of
IPv4 allocations/assignments to be transferred, including
IPv4 from special purpose blocks (reserved blocks for IXPs
and DNS root ops, Last /8, etc.)<br>
<br>
The current intra-RIR transfer policy does not cover ASNs
while there are cases where transfers of ASNs among AFRINIC
members is desirable.<br>
<br>
<br>
2. Summary of how this proposal addresses the problem<br>
<br>
This new policy defines a set of rules to allow transfer of
IPv4 addresses and ASNs within AFRINIC service region and
between AFRINIC service region and other regions by
specifying what categories of resources are eligible for
transfer, the location of parties (sources and recipients)
and the conditions to be met.<br>
The policy segregates the resources in different categories
and defines which transfer rules applied to each category.<br>
<br>
Only Legacy resources and resources previously transferred
from other regions will be transferable out of the AFRINIC
service region.<br>
<br>
It also states the following:<br>
<br>
Number resources are non-transferable and are not assignable
to any other organisation unless AFRINIC has expressly and
in writing approved a request for transfer. AFRINIC is
tasked with making prudent decisions on whether to approve
the transfer of number resources.<br>
<br>
IPv4 addresses and ASNs can be transferred only in
accordance with the following policy. AFRINIC does not
recognise transfers outside of this policy and its
predecessor and requires organisations holding such
resources to return them to the appropriate registries.<br>
<br>
The goal of this transfer policy is to help distribute
resources from those who no longer need them to
organisations that need the resources, but cannot obtain
them from the AFRINIC free pools.<br>
<br>
AFRINIC recognizes the following types of transfers:<br>
- merger, acquisition or takeover,<br>
- between AFRINIC members,<br>
- between an AFRINIC member and a member of another RIR,<br>
- between a Legacy holder and an AFRINIC member,<br>
- between a Legacy holder and a member of another RIR. <br>
<br>
AFRINIC will process and record Inter-RIR resource transfers
only when the counterpart RIR has an Inter-RIR transfer
policy that permits the transfer of IPv4 address space and
ASNs between its own region and AFRINIC.<br>
<br>
<br>
3. Proposal <br>
<br>
3.1 Definitions<br>
<br>
3.1.1 ?Resource? refers to IPv4 Address space or Autonomous
System Numbers.<br>
?AFRINIC pool? means AFRINIC managed pool of IPv4 and ASNs,
obtained from IANA (allocated and recovered) or through the
ERX (Early registration transfers).<br>
<br>
3.1.2 ?Special-Purpose pool? means the pool of resources
currently reserved for Critical Internet Infrastructures
(section 5.6.4 of CPM) and last /8 (section 5.4.1 of CPM).<br>
<br>
3.1.3 ?Legacy resources? refer to resources allocated prior
to the RIR system and tagged as Legacy by AFRINIC. <br>
<br>
3.1.4 ?Others? means resources transferred from other
regions through Inter-RIR transfer.<br>
<br>
3.1.5 ?Inter-RIR transfer? means the transfer of resources
from an AFRINIC member to a member of another RIR or
vice-versa.<br>
<br>
<br>
3.2 Marking of the resources<br>
<br>
AFRINIC pool == Regional<br>
Special-Purpose pool == Reserved<br>
Legacy == Legacy<br>
Others == Global<br>
<br>
3.3 Rules and procedures for selecting resources eligible
for transfers<br>
<br>
3.3.1 If source and recipient are AFRINIC members, then
allow ?Regional?, ?Global? or ?Legacy? for transfer and mark
transferred ?Legacy? as ?Global?<br>
<br>
3.3.2 If source is Legacy holder and recipient is AFRINIC
member, then allow ?Legacy? for transfer and mark
transferred resources as ?Global?<br>
<br>
3.3.3 If source is Legacy holder and recipient is in another
region, then allow ?Legacy? for transfer<br>
<br>
3.3.4 If source is AFRINIC member and recipient is in
another region, then allow ?Global? for transfer<br>
<br>
3.3.5 If source is from another region and recipient is
AFRINIC member, then allow ?Any?, and then mark the
transferred resources as ?Global?<br>
<br>
3.3.6 Irrespective of the source and recipient, if resource
to be transferred is ?Reserved? then deny transfer.<br>
<br>
3.4 Conditions on resources to be transferred<br>
<br>
- The size of the IPv4 address should be a minimum of /24.<br>
- The resource must qualify for type of transfer requested.<br>
- The resource will be covered by AFRINIC policies after
transfer into the region.<br>
<br>
3.5 Conditions on the source<br>
<br>
- Must be right holder of the resources to be transferred
with no disputes.<br>
- If the source is from other regions, conditions on the
source are defined in the counterpart RIRs transfer policy.<br>
<br>
3.6 Conditions on the recipient<br>
<br>
- Will be subject to current AFRINIC policies.<br>
- Must sign RSA.<br>
- Recipient that does not have prior resources must:<br>
++ demonstrate a detailed plan for the use of the
transferred resources<br>
(in the case of ASN, recipient must meet the criteria for
assignment of ASN).<br>
- Recipient with prior resources must:<br>
++ demonstrate a detailed plan for the use of the
transferred resources<br>
(in the case of ASN, recipient must meet the criteria for
assignment of ASN).<br>
++ Show past usage rate.<br>
++ Provide evidence of compliance with AFRINIC policies with
respect to past allocations/assignments.<br>
- If the recipient is in another region, the conditions on
the recipient are defined in the counterpart?s RIR transfer
policy.<br>
<br>
4. Revision History<br>
<br>
v1 submitted on 29/08/2019 for discussions <br>
<br>
5. References<br>
<br>
<a href="https://www.nro.net/wp-content/uploads/NRO-Statistics-2019Q2.pdf" rel="noreferrer" target="_blank">https://www.nro.net/wp-<wbr>content/uploads/NRO-<wbr>Statistics-2019Q2.pdf</a><br>
<a href="https://www.potaroo.net/tools/ipv4/" rel="noreferrer" target="_blank">https://www.potaroo.net/tools/<wbr>ipv4/</a><br>
<a href="http://bgp.potaroo.net/iso3166/v4cc.html" rel="noreferrer" target="_blank">http://bgp.potaroo.net/<wbr>iso3166/v4cc.html</a><br>
<a href="http://resources.potaroo.net/iso3166/ascc.html" rel="noreferrer" target="_blank">http://resources.potaroo.net/<wbr>iso3166/ascc.html</a><br>
<a href="ftp://ftp.afrinic.net/stats/afrinic/transfers/" rel="noreferrer" target="_blank">ftp://ftp.afrinic.net/stats/<wbr>afrinic/transfers/</a><br>
<br>
===================end========<wbr>===============<br>
<br>
<br>
<br>
<br>
------------------------------<br>
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End of RPD Digest, Vol 155, Issue 27<br>
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</blockquote>
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