Inbound Transfer Policy

 

Details

Ref. Name: AFPUB-2016-GEN-002-DRAFT-01 Submitted: 17 June 2016 Status: Expired Author: - Andrew Alston (This email address is being protected from spambots. You need JavaScript enabled to view it.) - Christopher Mwangi (This email address is being protected from spambots. You need JavaScript enabled to view it.) Staff & Legal Assessment and Comments

1)Summary of the Problem Being Addressed by this Policy Proposal

The AfriNIC Service Region has the lowest amount of IPv4 space of any of the RIR defined regions. As such, when AfriNIC depletes its current space, there will still be a need for further IPv4 addresses on the continent. In addition to this, there may be circumstances where companies wish to use specific v6 resources and ASN’s unavailable on the continent.

 

While the community has voiced concerns that enacting a transfer policy will result in the flow of resources off the continent, this policy addresses that by purely catering for inbound transfers, without allowing or affecting transfers flowing out of the continent to other RIR service regions.

 

2) Summary of How this Proposal Addresses the Problem

This policy covers the inbound transfer of all IP resources, including ASN’s, both 16bit and 32bit, IPv4 space and IPv6 space

 

3) The Proposal

Details of inbound transfer requirements

3.1) AfriNIC shall accept all inbound transfers of all resources explicitly referred to in section 2

 

3.2) For transfers into the region, the recipient of IP space (v4 or v6) must provide a plan to AfriNIC for the use of at least 50% of the transferred resource within the next 5 years.

 

3.3) Once received, the space shall form part of the recipient’s normal allocations for the purpose of evaluating the size of the recipient from an AfriNIC membership perspective.

 

3.4) Should a recipient of transferred space apply for further resources from AfriNIC directly, all space received via transfers shall be included in any evaluation done for further resource allocation by AfriNIC.

 

4.0 Revision History

17 June 2016: AFPUB-2016-GEN-002-DRAFT-01 posted to mailing list

 

5.0 References

None

 

 

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Staff & Legal Assessment and Comments

Staff Comments:

• The wording of section 3.1 is not clear about what "inbound" means, but we understand that this proposal covers inter-RIR transfers, from some other RIR to AFRINIC, for use by an AFRINIC member.
• "This policy covers the inbound transfer of all IP resources, including ASN’s, both 16bit and 32bit, IPv4 space and IPv6 space. "A currently ratified policy requires that AFRINIC makes no distinction between ASNs, so we suggest removing the words "both 16bit and 32bit"
• “3.2 For transfers into the region, the recipient of IP space (v4 or v6) must provide a plan to AFRINIC for the use of at least 50% of the transferred resource within the next 5 years.”The allocation period is 12 months currently and decreases when we reach soft-landing. 5 years causes a mismatch with the 12 months stated in the CPM
• We understand that there is no requirement for the recipient of the resources to comply with requirements stated in other policies, but there is a requirement in section 3.2 for the recipient to provide a plan for using 50% of the resources in 5 years. We understand that there is no requirement for the use to be efficient, in contrast to requirements in almost all other policies.
• We understand that, if the recipient of the space has been using it inefficiently under section 3.2, but then applies for more space under section 3.4, then section 3.4 effectively removes the licence for inefficient use.
• Section 3.1 refers to to section 2. Section 2 is not formally part of the proposal, it is merely a summary to aid discussion, and section 3 should be written so that it can stand alone.

Other Queries:

1. Should recipient be a current AFRINIC resource member or any organization (in which case a request for membership can be processed but dependent on approval of an inbound transfer?)
2. Will IP resources transferred be included in the AFRINIC resources inventory?
3. Who can initiate a transfer? Source or recipient?
4. Does any communication need to happen between RIRs for these requests? 
5.  “3.1 AFRINIC shall accept all inbound transfers of all resources” - No conditions are mentioned/applied here. Does it imply that: 

• It does not matter if the source or recipient are involved in any dispute as to the status of the resources (eg bad standing or non-compliance to other policies)? The inter-RIR transfer policies of the source RIR are for example not mentioned in here, and if they should be considered or not.
• Can Legacy Resource Holders from other RIRs transfer to our service region and AFRINIC has no other choice but to accept the transfer?  

• There is a grey area on whether legacy resource holders are covered by this and what shall happen to their membership category in case they are covered by the proposal. Sections 3.3 and 3.4 only covers a scenario for members, no mention of legacies.
  
  Tentative Assessment from other RIRs is indicative of the following:

• ARIN - cannot implement - need reciprocal
• RIPE - may (or may not) implement - yet to advise on details and requirements.
• LACNIC - Not applicable as no Inter RIR transfer policy
• APNIC - cannot implement - need reciprocity.