AFRINIC-28 | Public Policy Meeting - PPM Minutes - AFRINIC - Regional Internet Registry for Africa

Policy Development Process (PDP)

AFRINIC-28 Public Policy Meeting

09th May 2018 – Dakar, Senegal

Policy Development Working Group Discussion Minutes

PDF Version

Session Co-chairs:

Adewole Ajao (Nigeria)

Sami Salih (Sudan)

Discussions Outcomes/Co-Chair Decisions:

Proposal	Outcome/Decision
IPv6 Policy & References Update AFPUB-2018-V6-001-DRAFT01	Last Call
Internet Number Resources Review by AFRINIC AFPUB-2016-GEN-001-DRAFT06	More discussion needed
IPv4 Soft Landing - bis AFPUB-2016-V4-001-DRAFT07	More discussion needed
Policy Development Process – bis AFPUB-2017-GEN-002-DRAFT03	More discussion needed
Clarification on IPv6 sub-assignments AFPUB-2018-V6-002-DRAFT01	More discussion needed
IPv6 PI Update AFPUB-2018-V6-004-DRAFT01	Last Call
IPv6 Initial Allocation Update AFPUB-2018-V6-003-DRAFT01	Last Call

Agenda

Time	Items
09:00 - 09:30	1 - Welcome Remarks (Dewole Ajao) 2 - Agenda Overview and Adoption(Dewole Ajao) 3 - Overview of the AFRINIC Region PDP (Dewole Ajao) 4 - Policy Implementation Experience Report (Madhvi Gokool) 5 - Policy Update & News from other RIRs(Madhvi Gokool)
09:30 - 10:00	6 - Elections: (Wale Adedokun, Arthur Nguessan) 6.1 - PDWG Co-Chair Election 6.2 - Election of Members of the PDWG Appeals Committee (Seats 3, 4, 5)
10:00 - 10:30	7 - Policy Proposal AFPUB-2018-V6-001-DRAFT01 IPv6 Policy & References Update (Jordi Palet Martinez)
MORNING BREAK
11:00 - 11:45	8 - Policy Proposal AFPUB-2016-GEN-001-DRAFT06 Internet Number Resources Review by AFRINIC (Arnaud Amelina, Jean-Baptiste Millogo, Marcus Adomey)
11:45 - 12:30	9 - Policy Proposal AFPUB-2017-GEN-002-DRAFT02 Policy Development Process – bis (Komi Elitcha, Arnaud Amelina, Alain Aina, Honest Honella)
LUNCH
14:00 - 14:45	10 - Policy Proposal AFPUB-2016-V4-001-DRAFT07 IPv4 Soft Landing – bis (Alain Aina)
14:45 - 15:30	11 - Policy Proposal AFPUB-2018-V6-002-DRAFT01 Clarification on IPv6 sub-assignments (Jordi Palet Martinez)
AFTERNOON BREAK
16:00 - 16:30	12 - Policy Proposal AFPUB-2018-V6-003-DRAFT01 IPv6 Initial Allocation Update (Jordi Palet Martinez)
16:30 - 17:00	13 - Policy Proposal AFPUB-2018-V6-004-DRAFT01 IPv6 PI Update (Jordi Palet Martinez)
17:00 - 17:30	14 - AOB & Open Microphone (Dewole Ajao)

1.0 Welcome Remarks

Delegates were welcomed to the meeting (by Dewole Ajao, PDWG Co-Chair) who advised that while engaging in discussion, all engagement should be civil and devoid of personal attacks – citing the need for everyone to adhere to the AFRINIC code of conduct (highlights from which were read out).

2.0 Agenda Overview and Adoption

There were no requests to modify the draft agenda as initially announced.

3.0 Overview of the AFRINIC region PDP

The AFRINIC region Policy Development Process was explained to delegates by Dewole, who shared some highlights and other points as follows:

The PDP is in itself a policy, and any modifications to it, such as the currently proposed “AFRINIC PDP – bis”, must go through the current PDP.
This face to face discussion of active policy proposals at an AFRINIC public policy meeting is provided for in the PDP, after new policy proposals have been discussed on the mailing list for at least 30 days.
The current stipulation in the PDP requiring a proposal to not be changed at least 1 week to the public policy meeting appears too short, as 7 days is not ample time for staff to effectively conduct a thorough assessment of such a proposal. Dewole advised that 3 weeks is more reasonable.
Often times, individuals tend to get overly emotional and disrespectful to others, which makes co-chairs job difficult, and urged all to engage maturely.
Delegates were encouraged to share their thoughts on how co-chairs can improve their engagement efforts and ways to increase on the current policy development participation by the community, and share these thoughts during the Open Microphone session (or on the rpd list).

4.0 Policy Implementation Experience Report

Madhvi noted that the purpose of this report is to provide feedback to members and the community about recently ratified policies and their implementation timeline, ratified policies that have been recently implemented, experiences by staff in interpreting policy stipulations while evaluating members’ resource requests and sharing with the community the staff thoughts on sections of the CPM that may be irrelevant or ambiguous.

Key highlights from the report were as follows:

The recently ratified policy proposal AFPUB-2017-DNS-001-DRAFT02 (Lame Delegations in the AFRINIC reverse DNS) is scheduled for implementation on 01St June 2018.
The policy “IPv4 Resource Transfer within the AFRINIC region” was implemented in February 2018. Consequently, AFRINIC now accepts “intra-region” transfers from both AFRINIC members are Legacy Resource Holders. It was noted that transferrable resources types are only IPv4 addresses, unless the policy is updated to include others (such as ASNs and IPv6 address space). It was also noted that there is a guideline document that caters for “Mergers and Acquisitions”, which same document allows all resource types to be transferred in case of a Merger and/or Acquisition matter.
The IPv4 Soft Landing policy (CPM 5.4) presents some ambiguities around the 90% utilization requirement, which conflicts with the 80% utilization requirements for subsequent resources in other sections of the CPM.
Members do not seem to register abuse contact information for issued resources effectively and the community may want to guide on how this can be improved.
The community are encouraged to study the CPM and if necessary, address any ambiguities through the provisions of the PDP.

5.0 Policy Update & News from other RIRs

Policy updates from different RIR communities were shared by the respective RIR representatives present as follows:

ARIN – by Leslie Nobile

The following are all recommended draft policies which are in final review phase by the ARIN Advisory Council, to be sent to the Board for ratification.

2017-3: Update to NRPM 3.6: Annual WHOIS POC Validation: This specifies which organizations and Point of Contact records (POCs) are included in ARIN's annual POC Validation, and details how this validation is performed. It also directs staff to mark POCs that do NOT pass this validation as "invalid" and restrict their associated ARIN Online account access to payment and contact information update functionality.
ARIN-2017-8: Amend Community Networks: This updates the definition and policy language for Community Networks, allowing for a single /40 allocation under the policy. Allocations approved with this policy will only be allowed to reassign blocks from this space, no reallocations will be allowed.
ARIN-2017-10: Repeal of Immediate Need for IPv4 Address Space (NRPM Section 4.2.1.6): This removes section 4.2.1.6, which requires justification to show that the address space requested will be utilized within 30 days of the request, a section that has not been used since the IPv4 free pool depleted in September 2015.
ARIN-2017-12: Require New POC Validation Upon Reassignment: This adds an additional step to all requests for reallocations or detailed reassignments that will result in the creation of a new Point of Contact record (POC), which includes a ten-day window for the POC to validate the request information. If the proposed POC does not validate the information, the request will be rejected.
ARIN-2017-13: Remove ARIN Review Requirements for Large IPv4 Reassignments/ Reallocations: This removes a section of the Number Resource Policy Manual (NRPM) that required ARIN review of reassignments larger than a /18 or /19 depending on organization size.

APNIC – by Madhvi Gokhool

Proposal 118: No need policy in APNIC region: Removes the requirement to demonstrate need when transferring IPv4 addresses into or within the APNIC region with the exception where resources are from an RIR region requiring needs-based policies, where recipients must provide a plan to use of at least 50% of the resources within 5 years. This does not apply to AS number transfers. The proposal was initially discussed at APNIC 44, still no progress at APNIC 45 and may be resubmitted for APNIC 46.
Proposal 119: Temporary transfers: Proposal allows temporary transfers of IPv4 space. It is essentially similar to regular transfers, but with an end-date after which the registration will revert to the original holder. The proposal was initially discussed at APNIC 44, still no progress at APNIC 45 and may be resubmitted for APNIC 46.
Proposal 120: Final /8 pool exhaustion plan:Provides better refinement guidance for the 103/8 pool exhaustion. Once a request cannot be fulfilled from the Final 103/8 pool, a waiting list that will be established. APNIC would manage two waiting list pools - the recovered pool and the 103/8 pool. The proposal is still under discussion.
Proposal 123: Modify the 103/8 IPv4 transfer policy: Allows the transfer of 103/8 addresses without the five year restriction for delegations made before 14 September 2017. The proposal has been returned to authors for further consideration and submission of a revised version.
Proposal 124: Clarification on IPv6 Sub-Assignments:Clarifies the definition of assigned address space for IPv6 delegations under section 2.2.3 of APNIC Internet Number Resource Policies document by allowing temporary sub-assignments from within existing IPv6 assignment. The proposal will be discussed at APNIC 46.
Remote participation in SIG decisions: This proposal allow remote participation in consensus processes and for voting in SIG Chair Elections.Some aspects of remote voting may need further discussion. There has been strong support for remote participants to be included in decision making, but with adesire for additional stringent identity checks for remote participants. The APNIC Executive Council is yet to endorse the proposal for implementation.

RIPE – by Madhvi Gokhool

Regular abuse-c validation: Introduces a new abuse-c attribute in inetnum, inet6num and autnum whois database objects. It will reference a “role” object, which will contain contact information to be used for abuse incidents.
Organization LIR clarification in the IPv6 policies: Clarifies wording used in the policy document RIPE-699 regarding “organizations” and “LIRs” and tries to align these with the IPv4 policy documents.
Assignment Clarification in the IPv6 policy: This proposal is meant to improve on the definition of “assign” in the Section 2.6 of policy document RIPE-699
Fixing outdated information in the IPv4 policy: Fixes outdated text in the policy “IPv4 Address Allocation & Assignment Policies for the RIPE NCC Service Region”. This task was given to the Address Policy Working Group (APWG) by the community during RIPE75.
PDP Clarification: Proposes to fix some ambiguities around the “Review Phase” in the RIPE region Policy Development process (PDP)

LACNIC – by Madhvi Gokhool

Proposal to create a Global Internet Registry (GIR): Proposes the creation of a virtual RIR that would be responsible for assigning IP addresses and Autonomous System Numbers to organizations without a well-defined, single regionalization (i.e., to organizations that are global by nature and can effectively prove they have operations in more than one region).
Similar to some of the IPv6 related proposals @AFRINIC:

LAC-2018-4: Review and correction of errors in the IPv6 policy.

LAC-2018-7: Clarification of IPv6 Sub-Assignments.

Both aim to clarify some outdated text in the IPv6 policies within LACNIC community

Simplifying the PDP (Mailing List + Forum Option) : The proposal seeks to standardize the PDP by eliminating the requirement that consensus must only be reached at a public policy meeting. It maintains the meeting as a mandatory step for any proposal, but consensus must cater for mailing list discussions too. It clarifies ‘consensus’, which is often confused with ‘voting’, clarifies the purpose of the “so called” ‘last call’ and proposes an appeal process to be used for policy development dispute resolution.
Updates to the IPv4 allocation & assignment policies:

LAC-2018-9: Update to the Policy on Initial IPv4 Allocations to ISPs

LAC-2018-8: Update to the Policy on IPv4 Assignments to End Users

The proposals eliminate, among others, the multihoming requirement, to align IPv4 requirements with those of IPv6.

Registration and validation of ”abuse-c" and "abuse-mailbox”: Introduces the requirement to attach abuse contact information to ASN records. (The current (ASN) policy is not clear regarding the obligation to register an abuse contact (abuse-c) or its specific format, nor as to whether this applies to other whois records. This proposal aims to solve the problem and ensure the existence of a proper abuse-c contact and the process for its utilization.)
IP-Based Geolocation : This policy proposal seeks to publish/announce the (geo)location of an IP address in a simple and public manner to facilitate its geolocation. This makes it easy to establish the location of an IP address from whois records.

It was observed that the policy proposal to create a Global Internet Registry may be against the principles of ICP-2, and that the ASO-AC has been tasked to advise LACNIC and the community on any constraining matters. However, an ASO-AC member stated that there is so far no advice to give (by the ASO-AC) on the matter.

6.0 Elections

6.1 PDWG Election

The NOMCom Chair introduced the single nominee/candidate for the PDWG co-chair election – Mr Mark Elkins (from South Africa) and stated that there were initially three nominations, but before final slate release, two nominees withdrew from the race. Mark was called to speak to the community.

Mark introduced himself as an AFRINIC Member (through his affiliation with Posix Systems as CEO), and stated that he’s served on the Board and on the NomCom in the past. He indicated that he’s authored some policies before and is therefore well conversant with the PDWG co-chair job.

Comments from the floor (in reaction to Mark’s speech) arose as follows:

It was clarified that eligible voters are only those present in the room, and that remote participants are not allowed.
As Mark Elkins has proposed a motion to dissolve the entire AFRINIC board, he does not seem to have the interests of the community.
Mark appears to have the qualifications for the PDWG co-chair job.
There are younger people that can contribute better.

The Elections Committee asked for a show of hands for those in favor, and those not in favor of Mark Elkins’ candidature. After a show of hands, there were 22 in favor and 56 not in favor of Mark’s candidature.

NomCom Chair called for nominations from the floor to fill the empty PDWG co-chair seat.
There were suggestions that the position be filled by a temporary co-chair until there’s another nominations process to find a replacement co-chair.
Sami Salih (the outgoing co-chair) offered to continue as co-chair till there is a process in future to find a new co-chair.
Delegates were asked if there is support for Sami to continue as co-chair till the next scheduled nominations period. There was strong support to have Sami continue – and he was therefore tasked to serve as temporary co-chair until the next scheduled nominations season.

6.2 Election of Members of the PDWG Appeals Committee (Seats 3, 4, 5)

The NomCom Chair indicated that out of the 4 original nominees, candidate Kodzo Adomey withdrew his candidature hours before the election. The ballot papers had already been printed though with his name, and therefore, voters were advised to take note that the only candidates up for election are Wafah, Luc and Jean-Robert.

Voting/election results were as follows: Invalid: 5, None of The Above: 4, Jean-Robert: 91, Luc: 80, Wafah: 92. The three individuals Jean-Robert, Luc and Wafah are therefore elected to the PDWG Appeals Committee to fill the 3 empty seats.

7.0 Policy Proposal AFPUB-2018-V6-001-DRAFT01 - IPv6 Policy & References Update

The author (Jordi) shared the following highlights from the proposal:

There are some text contradictions in current policy text, which need to be aligned.
Proposal does not affect how AFRINIC issues IPv6 space, nor the justification information.
The concept of “utilization” is better clarified by the new proposal. (Not how many addresses are being used, but rather the prefix sizes).
The policy manual seems to interchange LIRs and ISP freely, which is being aligned.
Some text about assigning a /128 is being removed, since the reference RFC has since been updated.
No need to justify small /48 assignments, and this text would need to be deleted from the policy manual.
Similar changes have been made in other registries, and near-identical changes have been accepted by the LACNIC community recently.

AFRINIC staff indicated that the proposal can be implemented as written with no impact to any AFRINIC operations.

After some discussions and based on strong support from the Policy Development Working Group, there was little opposition and no recommendations to update any of the proposal text. Co-chairs decided that there was consensus on the proposal and moved it to “last call” in accordance with the provisions of the PDP.

Decision: Proposal advances to Last Call

8.0 Policy Proposal AFPUB-2016-GEN-001-DRAFT06 - Internet Number Resources Review by AFRINIC

The proposal was presented by Arnaud Amelina, who shared the following information:

Updates from version 5 were to remove categories of members that can be audited, and added the possibility to have member audited randomly.
All legal issues were addressed by authors, with no new issues raised by legal.
All staff issues were also addressed by authors, with no new issues raised by staff.

AFRINIC staff noted that in 13.4a (duration of time that AFRINIC can put in place for those in breach to be compliant) and 13.4c (reissue of resources - there is a quarantine period that is in place before resource re-issue of reclaimed resources) – authors noted that these are staff internal procedures that will be left for staff to implement as appropriate.

Reactions from the working group:

This proposal could allow for members to be targeted by unjust review requests that are spurious and malicious in nature.
If the audit was found to be unjustified, which party would incur the cost.
Since there are mechanisms in the RSA that allow for reviews to take place, this policy appears unnecessary.
Some comments against the proposal indicated that the policy is bad, overreaches, creates opportunities for abuse, and should be dropped.
Others in support indicated that the proposal will institute better and efficient management of number resources.

Authors’ reactions:

Proposal beefs up mechanisms already in place to have more command of the management of the resources.
There is already an RSA that mandates these reviews. The proposal is not creating the audits, but rather determines how to effectively perform them.

After several discussions, there was both strong opposition and strong support for the policy proposal for a variety of reasons as expressed above. Co-chairs decided to return the proposal to the mailing list for further discussions and refinement.Co-chairs also suggested that the community discuss further to see if there are better ways for AFRINIC to tackle the perceived/observed problem of irresponsible use of (or fraudulent applications for) Internet numbering resources.

Decision: Returned to list for more discussion

9.0 Policy Proposal AFPUB-2017-GEN-002-DRAFT02 - Policy Development Process – bis

The co-authors (Alain and Abel) shared the following remarks from the proposal:

The current PDP has some limitations that are constantly obvious whenever policy discussions are happening, and it seems there’s agreement that it needs to be improved.
There will be a new “adoption phase” for policy proposals, so that a “problem statement” can be formally adopted before a proposal can be discussed, in the “discussion phase”.
In the discussion phase, proposals must mature and go to the “review phase”.
Only proposals in “review phase” can make it for presentation to the community at the face to face meeting.
Next phase would be “last call” or concluding phase, after successful adoption at the face to face meeting.
A working group guideline, as part of the PDP, details roles of co-chairs before, during and after the meeting, and suggests improvement around electing/removing and resignation of chairs.

Feedback from the community included removal of absolutes, inclusion of additional definitions, addition of time for co-chairs to make consensus calls, more explicit text to take the contributions on RPD into consideration, addressing the subjectivity (based on individual perspective) of “minor” or “major” issues/objections, co-chairs as editors, CEO as chair, Council of Elders inclusion and allowing anonymous proposers among others.

Authors expressed willingness to continue engagement to move the policy proposal forward. As a result of so many areas requiring discussion, co-chairs returned the proposal to the RPD list for further discussion and refinement.

Decision: Returned to list for more discussion

10.0 Policy Proposal AFPUB-2016-V4-001-DRAFT07 - IPv4 Soft Landing – bis

Alain shared the following points from the proposal:

This proposal was submitted in February 2016, and attained rough consensus after its 7th iteration, but there was an appeal thereafter.
The appeals committee reversed the co-chairs’ decision, but did not make any observations to justify their decision, nor make any recommendations.
Authors expected the appeals committee to specify the specific objections that were never addressed by the authors.

Reactions from the floor:

The appeals committee ruling is final, and there is no process to dispute their decision.
Authors are encouraged to review the proposal and address the several objections, since there was a substantial section of the community that strongly opposed the proposal.
It appeared that the appeals committee usurped the co-chairs job to declare consensus. They should have looked at procedural matters instead.

Due to the pending discussions that still surround the proposal, co-chairs decided to return it the RPD list for more discussion and refinement.

Decision: Returned to list for more discussion

11.0 Policy Proposal AFPUB-2018-V6-002-DRAFT01 - Clarification on IPv6 sub-assignments

The author (Jordi) shared the following highlights:

When original policy was drafted, the concept of sub-assignments did not consider the use of PPP links and VPNs.
The issue of assigning a /64 to an interface needs to be clarified.
Space temporarily assigned to devices (via hotspots, etc) needs to be provided for in policy.
The same proposal has been submitted to RIPE and is also under discussion.

Staff asked if the “sub-assignments” under this proposal shall be recorded in WHOIS, to which the author clarified that these sub-assignments are temporary in nature and do not need to be registered.

There was good discussion on the proposal including some in relation to the wording and potential application to cover IPv4. Most of the feedback was positive even though some of it pointed to a lack of understanding of the proposal. As a result of the text-related feedback to which there was no conclusive modification, co-chairs decided to send the policy proposal back to the mailing list for further discussion and refinement.

Decision: Returned to list for more discussion

12.0 Policy Proposal AFPUB-2018-V6-003-DRAFT01 - IPv6 Initial Allocation Update

Highlights from the proposal:

Current policy text was done before real IPv6 deployment was possible.
Now we have the experience of new cases of big IPv6 deployments including government networks.
It necessary to align the text of subsequent allocations in order to be coherent and not discriminate LIRs with existing allocations. Historically, the process for requesting the default initial IPv6 assignment (/32 block) was very easy and, because many people were used thinking "the IPv4 way," they believed this would be large enough for their networks. For this reason, many ISPs don't prepare a proper addressing plan before requesting the proper prefix for the long-term deployment of their IPv6 network. Making sure that the policy text is aligned with a wider set of possible IPv6 deployment cases and facilitate the justification of the allocation size if a bigger address block (versus the default one) is requested.
Proposal ensures that the subsequent IPv6 allocation policy is synchronized with the initial allocation one.
It seeks to avoid unnecessary work for both parties: the ISP, who would be forced to renumber, and AFRINIC staff, who in any case would have to evaluate the new request and also provide a new prefix.

Staff confirmed that some of the issues raised are already being dealt with operationally but welcomed the proposed policy text.

Contributions included suggestions to use the policy proposal to enforce allocation alignment along nibble boundaries (an option the author chose not to deal with in order not to make the proposal more complex) and the need to remove requirements of announcing the space (an option the author agreed to). Based on strong support, absence of opposition, and consensus to update the proposal text, co-chairs moved the policy proposal to last call.

Decision: Proposal advances to Last Call

13.0 Policy Proposal AFPUB-2018-V6-004-DRAFT01 - IPv6 PI Update

Highlights from the proposal:

Since this policy was developed, IPv4 space has been exhausted and IPv6 deployment has evolved, so it doesn’t make sense to tie an IPv6 policy to the existence for IPv4 (same way as it is not tied the initial allocation policy).
In addition to that, because AFRINIC provided IPv6 PI at no cost to existing IPv4 PI holders, it may happen that the “default” assignment was requested without a proper addressing plan and this may not be the correct one at the implementation time.
This proposal updates the relevant text to accommodate the possibility to obtain IPv6 PI even if there is not IPv4 PI.
This proposal also adds a new section in order to allow a rectification of the initial assignment.
Several additions and changes to the CPM were presented as already detailed on the version published online.

Staff pointed out that the big ISPs are returning originally allocated /32 blocks in favor of larger blocks. Author was asked what actions to take if space is not announced in 12 months. There was also a need to clarify if the HD ratio principle is retained, plus whether AFRINIC should monitor the state of routing of issued IPv6 space. The author noted that the HD ratio portion of the current CPM is still intact, and that the staff are not under instruction to monitor routing.

Contributions included one (opposed to current version of proposal) which suggested leaving the current requirement to meet the same qualifications as IPv4 until IPv6 qualification criteria are defined. In spite of the singular objection, co-chairs moved the policy proposal to last call as there was no movement in the direction of text changes in the proposal.

Decision: Proposal advances to Last Call

14.0 AOB & Open Microphone

Issues were raised as follows:

Staff pointed out that assigned PA blocks are being registered in the AFRINIC WHOIS database in the name of entities that are not in fact customers of the resource holders. Cases in point are actually in the names of organizations outside the AFRINIC region who have complained to AFRINIC because they are not using those resources. To clarify, such WHOIS entries carry the misleading information in the comments fields. As these occurrences are showing up with legacy space holders, the more direct question to the community is “how do we deal with legacy space holders and others putting fraudulent data in our WHOIS?”
A community member pointed out that staff assessment of policy proposals should be made available at least 4 weeks in advance of the PPM to give authors and the PDWG time to act on the feedback before the PPM. Further clarification from the member seemed to suggest that staff should give their analysis within a week of receiving a new policy proposal.
It was observed that there is need for another review of the CPM to fix any references that may have broken in the insertion of new sections. It was suggested that staff do the review and present the results before the community for transparent adoption.
A community member suggested the need to propose a policy around abuse contact information as seems to be the case in the other RIR communities.
On remote participation, a request that transcripts of chat sessions be added to documentation/archives of PPM was observed.
There were comments made regarding the need for PDWG members to engage better on policy proposals well before the PPM.
Co-chairs raised the issue of mailing list moderation (especially Code of conduct violations) and called for volunteers that would like to assist in looking out for violations and moderating the mailing lists. In earlier discussion, it was pointed out that those who feel they are attacked in the course of discussions may contact the co-chairs directly with specific details of what they consider to be personal attacks or other code of conduct violation.