[arin-ppml] Inter-RIR transfer Policy compatibility with Afrinic_Resource Transfer Policy proposal

[Anthony Ubah]

Hello ARIN,

We are the authors 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 to inquire about its reciprocity with ARIN.

Feedback of your assessment and analysis of this proposal would be highly
appreciated.

Please find below the proposal for your reference.

We are looking forward to hearing from you.



*Draft Below......*

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 transfer5.7.3.1* 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 transfer5.7.4.1* 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.

*Best Regards,*

*UBAH ANTHONY*
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