Dear Taiwo and Address Policy WG, Thank you for submitting a request to the RIPE Address Policy Working Group.
Clarifying your message for the community: This version of the proposal “Resource Transfer Policy” (AFPUB-2019-V4-003) was published yesterday on the AFRINIC website as version 4, submitted on 5th of October 2020: https://afrinic.net/policy/proposals/2019-v4-003-d4#proposal Even though, as Taiwo states, it was initially announced that the proposal had reached consensus in AFRINIC, the working group chairs seem to have allowed one more week of discussion: https://lists.afrinic.net/pipermail/rpd/2020/011774.html The check for policy reciprocity for inter-RIR transfers is coordinated between the RIRs. There are some sections in this proposal which are not very clear and seem to impose some restriction on our own policies. We would need a bit more clarification on the intent of some of these parts before we can provide a final answer. For example, paragraph 5.7.4.2 does not take into account that we have resource holders in our service region that are not members of the RIPE NCC. We will ask AFRINIC for feedback on these points and we will provide them with our response. You can contact the AFRINIC policy officer for an update. When another RIR approves a policy proposal that impacts other RIRs (such as inter-RIR transfers with AFRINIC), we will inform the RIPE community accordingly. Kind regards, -- Petrit Hasani Policy Officer RIPE NCC > On 16 Oct 2020, at 13:34, Taiwo Oyewande <[email protected]> wrote: > > Hello, > > I am a co-author of the Resource Transfer Policy, which is the inter-RIR > transfer proposal that has just reached consensus within Afrinic, and we are > reaching out to you so as to inquire about its reciprocity with RIPE. > > Your assessment and analysis about this matter would highly be appreciated. > > Please find below the proposal for your reference. > > [ > > Resource Transfer Policy > > Authors: Anthony Ubah & Taiwo Oyewande > > Submission date: 21/09/2020 > > Version: 2.0 > > Amends: CPM 5.7 > > > 1. Summary of the problem being addressed by this proposal > > The current policy fails to support a two-way Inter-RIR policy, thereby > hindering smooth business operation, development, and growth in the region. > This proposal aims to establish an efficient and business-friendly mechanism > to allow number resources to be transferred from/to other regions. This > proposal outlines a model in which AFRINIC can freely transfer number > resources to/from other regions, i.e. RIPE NCC, APNIC, ARIN and LACNIC. This > includes both IPv4 addresses and AS numbers. > > 2. Summary of how this proposal addresses the problem > > With the exhaustion of IPv4, several regions have adopted a transfer policy > to accommodate the shortage of resources. Number resources are allowed to > transfer within the region itself, as well as with other regions. > Such practice is effective and necessary when we are facing a shortage of > resources. This helps facilitate business operations while reducing prices. > Such Inter-RIR transfer, however, is not yet established in AFRINIC. This > hinders business operation and development within the African region. The > current proposal aims to establish an efficient and business-friendly > mechanism to allow number resources to be transferred from/to other regions. > Before moving to illustrate how this new mechanism works, let’s take a quick > look at the situation of the current Consolidated Policy Manual: > In Consolidated Policy Manual updated on 22 Feb 2019, only “IPv4 resources > transfer within the AFRINIC region” is mentioned. > Regarding resource transfer to other regions, only the following is mentioned: > 5.5.1.1.3 If an LIR plans to exchange or transfer address space, it needs to > contact AFRINIC so that the changes are properly registered. > The LIR remains responsible for all the allocations registered in the AFRINIC > database until they have been transferred to another LIR or returned to > AFRINIC. LIR's must ensure that all policies are applied. > The lack of a clear guideline of resource transfer is detrimental to the > continent’s development. It makes business operation difficult and it also > hinders new business from establishing in the region. > Also, as Inter RIR policy is enforced in other regions, it is important that > AFRINIC keeps up with other RIRs to ensure smooth operation and coordination. > > 3. Proposal > > CPM 5.7 will be modified by this proposal as follows: > > 5.7 IPv4 Resources resource transfer > > Like the other Regional Internet Registries, AFRINIC will soon exhaust its > IPv4 pool. In order to meet the needs of late resource requestors, a transfer > policy for IPv4 resources within and outside the region is needed. The goal > of this policy is to define conditions under which transfers must occur. The > policy solves the issue of an African organization needing IPv4 number > resources after the exhaustion of the AFRINIC IPv4 pool or when AFRINIC can > no longer satisfy the needs of such an organization. > > 5.7.1 Summary of the policy > > This policy applies to any transfer request raised by a resource holder for > resource transfer to and from the AFRINIC region. > > 5.7.2 IPv4 resources to be transferred - must be from an existing AFRINIC or > any RIR member's account or from a Legacy Resource Holder. > > 5.7.3. Conditions on the source of the transfer > > 5.7.3.1 The source must be the current and rightful holder of the IPv4 > address resources registered with any RIR , and shall not be involved in any > disputes as to those resources' status. > > 5.7.3.2 Source entities are not eligible to receive any further IPv4 > allocations or assignments from AFRINIC for a period of twelve (12) months > after a transfer is approved. Incoming transferred resource cannot be > transferred again for a period of twelve(12) months. > > 5.7.3.3 There is no upper limit regarding the amount of transfer, allocation > and assignment of IPv4 number resources a source entity can receive as long > as the transfer request is carried out under a mutual agreement between the > source and the recipient. > > 5.7.4. Conditions on the recipient of the transfer > > 5.7.4.1 A transfer from another RIR to AFRINIC requires a need-based > evaluation. AFRINIC must approve the recipient's need for the IPv4 number > resources. In order for an organization to qualify for receiving a transfer, > it must first go through the process of justifying its IPv4 resource needs > before AFRINIC. That is to say, the organization must justify and demonstrate > before AFRINIC its initial/additional allocation/assignment usage, as > applicable, according to the policies in force. > > A transfer from AFRINIC to another RIR must follow the relevant policies. > > 5.7.4.2 The recipient must be an AFRINIC or any RIR member, legacy holders > in any region > > 5.7.4.3 Incoming transferred legacy resources will still be regarded as > legacy resources.] > > > > We are looking forward to hearing from you. > > Regards, > > Taiwo O
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