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

[Anthony Ubah]

Dear John,

Thanks for your prompt reply. I'd like to point out the value for us to
communicate directly rather than with intermediaries as it is a more
effective process.

5.7.4.2   The recipient must be an AFRINIC or any RIR member, legacy
holders in any region

This clause is never intended to put a limit on the other RIR’s recipient
requirement. It simply puts a requirement for the AFRINIC region.

As members are the only RIR customers in our region, it can be interpreted
as "the recipient can be customers of other RIR". Will ARIN accept such
clarification?

Or, would a rewording of “The transfer recipient must be an AFRINIC member
or any RIR member or legacy holders in any region, or any kind of entities
as other RIRs deem proper” better clarify our intention? We would prefer
not to modify policy text at this late stage of policy proposal, but if
ARIN insists, we will talk to the chairs in our policy community to see if
such editorial change would be acceptable.

As policy author, we are not lawyers, nor do we consult with lawyers while
we are writing policy proposal. We appreciate if ARIN can tolerate such
fine wording in the policy text and accept a more open “intention” oriented
interpretaion.

Thanks

Kind Regards,

Anthony Ubah

On Tue, Oct 13, 2020, 3:28 PM John Curran <jcurran at arin.net> wrote:

> On 13 Oct 2020, at 8:48 AM, John Curran <jcurran at arin.net> wrote:
>
>
> *1. Does the policy impose any conditions on recipient organizations in
>> the ARIN region receiving transfers from AFRINIC-served entities?*
>>
>
> *No. The final version of this proposal indicates clearly that no
> condition will be imposed on the recipient’s organization in other regions,
> which obviously also applies to the case of ARIN.*
>
>
> Anthony -
>
> We’re having trouble now reconciling your response above (regarding
> conditions of recipient organizations in the ARIN region) with the
> following statement in the provided policy text –
>
> *"5.7.4.2   The recipient must be an AFRINIC or any RIR member, legacy
> holders in any region”*
>
> The way the policy text is written makes it very challenging to determine
> what criteria are to be applied by AFRINIC versus criteria that are to be
> applied to organizations served by other RIRs, and that was the reason for
> our two questions about regarding conditions to be imposed on ARIN-region
> organizations.   Our plain reading of 5.7.4.2 suggests that it would need
> to be applied by ARIN to ARIN-region recipients.
>
> If this is the case, then the proposed policy is not compatible with
> ARIN’s NRPM 8.4 requirements for compatible transfer policies – as ARIN
> would need to (despite your earlier response) apply this “member legacy
> holder” criteria when processing requests by ARIN customers to receive
> number resources via InterRIR transfer from AFRINIC-served customers.
>
> I will observe that there is a real risk of incompatibility when RIRs
> write specific policy criteria to be applied by other RIRs; in this case,
> it is worth noting that not all ARIN customers are members or legacy
> resource holders, and thus the proposed policy as written would not be
> available to a significant portion of the ARIN community.  (This conflict
> also points out the value of staff involvement in formal review of proposed
> InterRIR transfer policies, as there are many details that need to align
> for smooth transfer processing.)
>
> Thanks,
> /John
>
> John Curran
> President and CEO
> American Registry for Internet Numbers
>
>
>
>
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