<html><head><meta http-equiv="Content-Type" content="text/html; charset=utf-8"></head><body style="word-wrap: break-word; -webkit-nbsp-mode: space; line-break: after-white-space;" class=""><br class=""><div><br class=""><blockquote type="cite" class=""><div class="">On Jul 2, 2021, at 10:36 , Fernando Frediani <<a href="mailto:fhfrediani@gmail.com" class="">fhfrediani@gmail.com</a>> wrote:</div><br class="Apple-interchange-newline"><div class="">
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<div class=""><p class="">So they are relying on a wrong option which should never have
relied. <br class=""></p></div></div></blockquote><div>What is your basis (specifically, section numbers please) in policy (CPM, RSA, or bylaws) for calling this “wrong”?</div><blockquote type="cite" class=""><div class=""><div class=""><p class="">
If they have needs for IPv4 (as everybody else) and they cannot
get these addresses directly from the RIR as per the current rules
which apply equally to everybody they have the option to use
Inter-RIR transfer policy available on all other RIRs.<br class=""></p></div></div></blockquote>But this option is not available to AFRINIC resource members at this time, so what should they do in this instance?</div><div><blockquote type="cite" class=""><div class=""><div class=""><p class="">
If these organizations are from outside Africa region then it is
even worst they grab unused addressed that were assigned to a
local company to use somewhere else out of the region.</p></div></div></blockquote>It seems to me that this is a moral judgment based strictly on your own opinion with no basis in policy. If you have a basis in policy for this argument, please present it.</div><div>Please be specific and cite the relevant sections of the governing document that you base your conclusion on.</div><div><blockquote type="cite" class=""><div class=""><div class=""><p class="">Not everything that is useful or convenient to some is correct
and as such should e stimulated and IP leasing mean the current
holder doesn't justify for those addresses anymore, so either it
gives it back to AfriNic or transfer them definitely.</p></div></div></blockquote>Again, this is a value judgment you are making without any valid basis in policy. If you believe there is such a basis, then please provide specific citation(s) showing same.</div><div><br class=""></div><div>Otherwise, kindly talk about what you believe should be policy rather than stating it as if it is fact.</div><div><br class=""></div><div>AFRINIC has done enough making up policy as they go along. It’s time to follow the policies as written. If you don’t like the policies as written, then there’s a process for changing them and you are completely free to submit a policy proposal to do so. If you need help figuring out the process, let me know. I will happily help you even though I will likely oppose your policy. I am all for a thorough debate of this topic around an appropriate policy proposal so that the community can make an informed choice once and for all and reduce the ambiguities that have plagued us so far.</div><div><br class=""></div><div>Owen</div><div><br class=""></div><div><blockquote type="cite" class=""><div class=""><div class=""><p class="">Regards<br class="">
Fernando<br class="">
</p>
<div class="moz-cite-prefix">On 02/07/2021 14:29, Mimi dy wrote:<br class="">
</div>
<blockquote type="cite" cite="mid:CAAtVZRc8U9a-sOWmdwupoy9scjjTb8tLuvHQhoLVN8_XQMg59Q@mail.gmail.com" class="">
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<div dir="ltr" class="">
<div dir="ltr" class="">Hello Fernando, </div>
<div dir="ltr" class=""><br class="">
</div>
<div dir="ltr" class="">
<div class="">Many organizations rely on IP Leasing in order to acquire
number resources quickly and affordably to meet their
current and future needs. It is totally legit, especially
during the IPv4 exhaustion phase, where resource scarcity
represents a real issue for ISPs and network-holders in
AFRINIC's service area.</div>
<div class="">I find it absurd that you are arguing against IP leasing
when it is a legal and accurate way to obtain IPs. Indeed,
there are some malicious organizations out there misusing
leased IPs, but that is certainly not the case for everyone,
so no need to generalize. Consequently, you cannot really
dismiss IP leasing using weak arguments as such. </div>
<div class=""><br class="">
</div>
<div class="">Since IP leasing is very helpful to numerous entities in
the period of shortage of available IP addresses, and is
certainly legal, I fail to understand why you are advocating
against it. </div>
<div class=""><br class="">
</div>
<div class=""><br class="">
</div>
<div class="">Best,</div>
<div class=""><span style="font-size: 16px; font-family: Gotham, Arial, Helvetica, sans-serif;" class=""></span></div>
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</span></div>
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<div class="gmail_quote">
<div dir="ltr" class="gmail_attr">Le ven. 2 juil. 2021
à 16:48, Fernando Frediani <<a href="mailto:fhfrediani@gmail.com" target="_blank" moz-do-not-send="true" class="">fhfrediani@gmail.com</a>> a
écrit :<br class="">
</div>
<blockquote class="gmail_quote" style="margin:0px 0px 0px
0.8ex;border-left-width:1px;border-left-style:solid;border-left-color:rgb(204,204,204);padding-left:1ex">Well,
like it or not but having a customer that is in the leasing
<br class="">
business may effectively change our opinion about some
subject, even if <br class="">
personally you wish it may not to.<br class="">
<br class="">
Trying to find an exact 'ipsis literis' word in the CPM that
fulfill or <br class="">
not your expectations may not always work. There is always
room for some <br class="">
interpretation and staff is the one responsible to do that
in this context.<br class="">
For the absurd leasing possibility is very simple: if
leasing proposes <br class="">
cannot be used as a justification to receive a new block
from the RIR <br class="">
why would it be after you receive it and missuse it for
different <br class="">
proposes other than bring connectivity to your customers. In
that sense <br class="">
I really hope staff stand strong in revoking resources that
are being <br class="">
used for leasing proposes, different from what they have
been justified <br class="">
originally and if necessary fight in courts of Mauritius to
have that <br class="">
decision preserved.<br class="">
<br class="">
For out of the region usage there have been multiple people
who showed <br class="">
that is not currently permitted. Maybe you don't agree with
that but <br class="">
bottom line is that is what staff has been interpreting from
the current <br class="">
rules backed by what some of us have put here based in
previous messages.<br class="">
<br class="">
Want to use AfriNic resources in a different region ? Simply
transfer <br class="">
them permanently using the soon-to-come Inter-RIR transfer
policy and <br class="">
bound to the rules of the new RIR.<br class="">
<br class="">
Regards<br class="">
Fernando<br class="">
<br class="">
On 02/07/2021 04:46, Owen DeLong via RPD wrote:<br class="">
> Full disclosure: I don’t personally have a dog in this
fight. I am personally<br class="">
> agnostic as to whether leasing should or should not be
permitted in a<br class="">
> newly developed policy.<br class="">
><br class="">
> I do have a client that I consult for which is in the
leasing business. It is my<br class="">
> opinion that their leasing business is 100% compliant
with policy as it is<br class="">
> written and that if the community doesn’t like that
fact, the community can<br class="">
> and should certainly amend the policy to rectify the
situation.<br class="">
><br class="">
>> On Jun 29, 2021, at 03:08 , Frank Habicht <<a href="mailto:geier@geier.ne.tz" target="_blank" moz-do-not-send="true" class="">geier@geier.ne.tz</a>> wrote:<br class="">
>><br class="">
>> Hi,<br class="">
>><br class="">
>> On 29/06/2021 12:01, Owen DeLong via RPD wrote:<br class="">
>>> nectivity customers or use out of the region as
something "normal and<br class="">
>>> acceptable".<br class="">
>>><br class="">
>>> Regardless of who does and does not benefit,
the reality is that short<br class="">
>>> of an actual government with the ability to
enforce its rules using<br class="">
>>> guns and prisons, people who can make a profit
are going to do what<br class="">
>>> they are going to do.<br class="">
>> I need to break this down.<br class="">
>> I'm working in my $dayjob for one of those
companies that are after<br class="">
>> $profit. What this company _did_ is subscribe to
the methods and rules<br class="">
>> of a Mauritius company called AfriNIC, in order to
get Internet<br class="">
>> Numbering Resources. And I think many of the
AfriNIC members formally<br class="">
>> subscribed to these rules. (And the rules are
subject to change<br class="">
>> according to PDP)<br class="">
>><br class="">
>> These INR are provided to members per need and
justification. Relatively<br class="">
>> recently additional rules came into force that
limited each allocation<br class="">
>> to maximum /22 - this is how rules can change.<br class="">
>><br class="">
>> INR are delegated to members that need them
themselves, and AfriNIC<br class="">
>> calls these members "End-User" members. They are
also delegated to<br class="">
>> members that provide internet access to respective
customers, and<br class="">
>> AfriNIC calls these members "LIR" members.<br class="">
> You are close, but the term used in the bylaws is “open
system protocol<br class="">
> network services”. I am not sure why such awkward and
broad language<br class="">
> was chosen, but that’s a much broader definition than
“internet access”.<br class="">
><br class="">
> In the CPM, LIR is defined as “An IR that receives
allocations from an RIR and primarily<br class="">
> assigns address space to 'end-users’. LIRs are
generally ISPs. Their customers are other<br class="">
> ISPs and possibly end-users. LIRs must be members of
AFRINIC.”<br class="">
><br class="">
> Again, there’s not a single word in that definition
that ties it to connectivity<br class="">
> services or internet access.<br class="">
><br class="">
>> I believe in all justifications for IPv4, LIR
members request/require<br class="">
>> the addresses to address customers, or servers, or
VMs that get<br class="">
>> connectivity services from the LIR member. And
there is no problem with<br class="">
>> that. LIR is in the business of making profit,
providing connectivity,<br class="">
>> hosting servers, services, needs IPs, gets IPs.<br class="">
> Certainly this is the prevalent model, whether or not
it is 100% pervasive<br class="">
> I am not sure.<br class="">
><br class="">
>> There is a big difference to the case where an LIR
member<br class="">
>> - has IPv4 address space,<br class="">
>> - is not using it themselves,<br class="">
>> - not for connectivity (or hosting) customers<br class="">
>> and has the IPv4 space used by "customers" that are
only getting the<br class="">
>> IPv4 space as a service - sold or leased.<br class="">
> Is there? So long as the customers in question are
justifying the space to the<br class="">
> same standards that an end-user applying to the RIR
would have to or to the<br class="">
> same standard that would be required if they were also
getting connectivity<br class="">
> from the LIR, then what exactly is the difference?<br class="">
><br class="">
> What if the LIR in question did announce the covering
aggregates of space<br class="">
> they leased and provided some minimal connectivity to
the customer in question?<br class="">
> Now they meet the definition you’ve provided above, but
they’re not actually<br class="">
> moving packets because the more-specific being
announced to the customer’s<br class="">
> higher bandwidth providers will win vs. the aggregate.<br class="">
><br class="">
> Does removing this connectivity fig leaf really change
the nature of the<br class="">
> assignment in a meaningful way?<br class="">
><br class="">
>> Is that the purpose for which the IPv4 space was
obtained and justified?<br class="">
> Since I don’t have access to anyone’s IPv4
justifications to AFRINIC in a<br class="">
> manner which would allow me to comment publicly, I’m
going to skip this<br class="">
> question. Suffice it to say, I can imagine a number of
ways in which this<br class="">
> is possible.<br class="">
><br class="">
>> There are "rules" that say an LIR should notify
when use of an IP block<br class="">
>> changes.<br class="">
> Yes. The rules are, however, ambiguous at best and it’s
not clear at what<br class="">
> level of detail a “change” is constituted nor is it
clear whether an update<br class="">
> to whois is adequate notification in most
circumstances.<br class="">
><br class="">
>> I see a big difference between changes *within an
LIR* and changes to<br class="">
>> *use the IP space outside the AfriNIC member LIR*.<br class="">
> So if I have space that was allocated to my LIR and I
assigned it to<br class="">
> customer A who is using the space in their network
(technically outside<br class="">
> of my LIR), but then they return the space when they
get their own<br class="">
> block and become a BYOA customer, my assigning that
space to customer<br class="">
> B for their use on their network (also outside my LIR)
becomes a problem<br class="">
> or change in the usage exactly why?<br class="">
><br class="">
>> With the first, I consider it generally accepted
that justification remains.<br class="">
>> With the latter, I believe that the *LIR that
subscribed to AfriNIC<br class="">
>> rules* has shown to no longer have the
justification for these IPs for<br class="">
>> connectivity and hosting, including "PA" customers.<br class="">
> What if the justification in question was not
“connectivity and hosting”?<br class="">
><br class="">
> What if the justification was “Numbering hosts on
customer networks”?<br class="">
><br class="">
>> The reason for doing the latter is obviously
$profit, and yes - some "<br class="">
>> are going to do what they are going to do ".<br class="">
> The reason for the former was obviously profit, too.
Nobody is in business<br class="">
> to subsidize the benefits of others without making a
profit.<br class="">
><br class="">
>> And what this community allows them to get away
with.<br class="">
> It’s not so much a question of “get away with” as “what
the rules actually<br class="">
> say” from my perspective. You may wish to argue that
the intent or even<br class="">
> the clear intent of the community is something else,
but in reality, for rules to be<br class="">
> useful, one must consider what the rules actually say,
and not the current<br class="">
> popular interpretation of intent around the rules.<br class="">
><br class="">
> Making it up as we go along has become somewhat of an
AFRINIC tradition<br class="">
> at this point, seemingly both in the staff actions and
in the board, PDWG,<br class="">
> community, and various committees.<br class="">
><br class="">
> There’s also a pretty strong history of doing so being
the source of a great<br class="">
> many problems, so I continue to hope that we can learn
from those mistakes<br class="">
> and start actually following the rules as they are
written and making the<br class="">
> changes necessary through the proper processes when the
rules do not<br class="">
> meet the perceived needs of the current situation.<br class="">
><br class="">
>> To be Frank: I simply don't believe that<br class="">
>> AS212552 "BitCommand" in Armenia gets IP
connectivity services from<br class="">
>> ... you know who.<br class="">
> Honestly, I don’t know who, but it’s easy enough to
look up:<br class="">
><br class="">
> <a href="https://bgp.he.net/AS212552#_irr" rel="noreferrer" target="_blank" moz-do-not-send="true" class="">https://bgp.he.net/AS212552#_irr</a><br class="">
><br class="">
> Says that they get apparent transit from AS64515 and
AS24940.<br class="">
><br class="">
> This seems to be borne out by <a href="https://bgp.he.net/AS212552#_graph4" rel="noreferrer" target="_blank" moz-do-not-send="true" class="">https://bgp.he.net/AS212552#_graph4</a><br class="">
><br class="">
>> In other continents / RIRs the IPv4 space is
finished. Noone has any<br class="">
>> hope of justifying any with the RIR. Some have more
than they need -<br class="">
>> give or sell it to others that have "a need" and
the market can probably<br class="">
>> regulate that.<br class="">
> ARIN is still issuing /24s under NRPM section 4.10, so
that’s not entirely<br class="">
> correct.<br class="">
><br class="">
>> But AfriNIC still has and is distributing IPv4 -
should it do so by<br class="">
>> "whoever pays most" or "everyone according to their
need [upto a /22<br class="">
>> ;-)]". Has it given IPv4 resources to members
according to their<br class="">
>> respective (perceived) needs???<br class="">
>><br class="">
>> Wasn't one of the rules that the LIR was to use the
IPs for the<br class="">
>> connectivity (or hosting) services?<br class="">
> I’ve reviewed the bylaws, the RSA, and the CPM pretty
carefully. I couldn’t<br class="">
> find a connectivity requirement other than one that
calls for the numbers<br class="">
> to be “routed on the internet” (which, btw, is a unique
requirement in<br class="">
> AFRINIC not present in other RIRs).<br class="">
><br class="">
>> Are the rules still applicable?<br class="">
> The rules still apply as written, but that’s the real
sticking point. Do we<br class="">
> want to focus on the common perception of what we think
the rules<br class="">
> say (as you have done above) or do we want to review
the rules as<br class="">
> they are written and call for the enforcement of those
rules according<br class="">
> to a plain text interpretation of their actual content?<br class="">
><br class="">
>> bit more below...<br class="">
>><br class="">
>>> I’m not particularly happy about this reality,
but I do recognize that<br class="">
>>> it is, in fact, reality and I’m not in favor of
giving RIRs guns or<br class="">
>>> the ability to incarcerate people. Contracts
only get you so far and<br class="">
>>> clever people can always find ways to comply
with the letter of a<br class="">
>>> contract while circumventing the other party's
intent if they want to<br class="">
>>> try hard enough.<br class="">
>>><br class="">
>>> So no, these are not “nice words”, they are the
recognition of<br class="">
>>> unpleasant and inconvenient truths that like it
or not, we are faced<br class="">
>>> with new realities, economic, technical, and
legal.<br class="">
>> Is one of these realities that an LIR got resources
from AfriNIC for<br class="">
>> providing connectivity (or hosting) services, and
now these are no<br class="">
>> longer in place?<br class="">
> I have no knowledge of such a situation, but in truth I
have not read<br class="">
> the original justification for the space issued to the
LIR I think you<br class="">
> are referring to.<br class="">
><br class="">
>>> In many countries legal frameworks the lack of
a transfer policy<br class="">
>>> allowing registrants to monetize the transfer
of their registrations<br class="">
>>> could be considered either restraint of trade
or an<br class="">
>>> anti-trust/anti-competitive matter.<br class="">
>> the fact is that these numbers should be unique and
centrally managed.<br class="">
>> These anti-trust lawyers can send a better proposal
for managing them.<br class="">
> The ability to sell one’s registration to another does
not in any way impinge<br class="">
> the central management of numbers for uniqueness.<br class="">
><br class="">
>> The question is whether "according to need" or
"according to whoever<br class="">
>> offers more $$".<br class="">
> This assumes that monetized transfers and/or leasing
cannot be done<br class="">
> on the basis of need, which is a false premise. To the
best of my knowledge,<br class="">
> Larus is quite scrupulous and detailed in collecting
need justification from<br class="">
> customers prior to issuing addresses to them. That is
certainly the written<br class="">
> company policy and has been the case with each and
every recipient<br class="">
> case I have been involved with in my consulting for
them.<br class="">
><br class="">
>> Should I be allowed to "buy" a /16 from AfriNIC,
put it in a safe, sell<br class="">
>> it 3 years later for $profit ???<br class="">
> No. The rules prohibit you putting it in a safe and not
routing it. Also, you<br class="">
> aren’t buying the /16, you are paying a fee for the
service of recording and<br class="">
> maintaining the registration of the space. You can’t
sell the integers, but<br class="">
> selling the registration of the integers has become
common practice<br class="">
> worldwide whether you like it or not.<br class="">
><br class="">
>> Is that the purpose for which AfriNIC got the /8's
from IANA?<br class="">
> Things have changed since the IANA was issuing /8s. The
world has changed.<br class="">
> Many of the /8s were issued by the IANA in order to
support Email, FTP, and<br class="">
> NNTP. I suspect there are very few servers running FTP
or NNTP these days,<br class="">
> and while EMAIL is still a pervasive technology (for
better or worse), it is not<br class="">
> a significant fraction of internet traffic.<br class="">
><br class="">
> Very few of the /8s issued by IANA were issued during a
time when streaming<br class="">
> video could have been considered as a purpose for
issuing them, yet today<br class="">
> it is probably the largest consumer of bandwidth on the
internet by far.<br class="">
><br class="">
> Should we require all of the RIRs that have issued
space to Netflix after<br class="">
> IANA runout to reclaim and return that space to IANA
and rejustify it because<br class="">
> streaming video was not the purpose for which it was
issued?<br class="">
><br class="">
> I think not.<br class="">
><br class="">
>> PS: all or most questions are serious. answers will
help.<br class="">
> All of the answers were serious as well. I’d expect
nothing less from<br class="">
> someone of your stature in the community.<br class="">
><br class="">
> I hope the answers are helpful.<br class="">
><br class="">
> Owen<br class="">
><br class="">
><br class="">
> _______________________________________________<br class="">
> RPD mailing list<br class="">
> <a href="mailto:RPD@afrinic.net" target="_blank" moz-do-not-send="true" class="">RPD@afrinic.net</a><br class="">
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