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

[Anthony Ubah]

Dear John:

Thank you for your prompt reply.

We agree that the efficiency of our RIR could be improved. As authors, we
only received the information regarding compatibility after the last call
has been announced while our local RIR should have worked with us on these
months before in order to have precise wordings for the proposal.

As for the final version, if I understand your previous email correctly,
the compatibility request hasn’t been officially sent to ARIN yet.
Generally speaking, other regions’ policy text are not as accurate and
“lawyer-proven” as that of ARIN, which I reckon you may agree with me.

Our region is running out of IPv4 space, therefore we feel urgently need an
inter-RIR transfer policy. Due to the pandemic Afrinic was unable to have a
smooth meeting, and we might not have a second policy meeting this year. We
hope that our policy can achieve compatible with that of ARIN as ARIN has
the largest IPv4 pools available in the world, while AFRINIC is the
smallest, accounting for only 3% of the world’s IP, which is inadequate in
comparison to a populationapproaching 1.5billion.
There is a need for an Inter RIR Policy, it should be not hindered because
of “fine writing of the policy text”. Also, as the policy author, we
believe that we still have the final say regarding the interpretation of
the intent of the policy text. By directly clarifying our intent of the
policy here with ARIN, we hope that ARIN can work with our current text and
allow Inter RIR Transfer to take place between our region and yours.

A future and better written text can be submitted through our PDP process
for future request (potentially next year). For now we hope that ARIN would
accept the policy in a way which is in accord with our initial intended
writing.

If ARIN insists on its own interpretation of the text, we will talk to our
chairs to see if one more editorial change can be made to facilitate your
requirement.

As the answer of ARIN on this topic is critical, we would be encouraged,
and appreciated if you could provide us an answer here, rather than going
though the lengthy inter-RIR communication process.


Kind regards,

Anthony Ubah

On Tue, Oct 13, 2020, 5:34 PM John Curran <jcurran at arin.net> wrote:

> On 13 Oct 2020, at 11:29 AM, Anthony Ubah <ubah.tonyiyke at gmail.com> wrote:
>
>
> 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.
>
>
> Anthony -
>
> Your local RIR is your best resource for such engagement, as they can help
> you with clarity of language and will ultimately need to implement any
> policy adopted in your region.
>
> We will continue to provide formal reviews of InterRIR transfer
> compatibility as requested by other RIRs – my only advice regarding
> inter-RIR transfer policy language is a suggestion to be explicit as
> possible about requirements imposed on those outside your region to the
> extent feasible.   No specific wording is necesary, but as means of an
> example, you can see how we handle the requirements in the ARIN NRPM 8.4
> clauses –
>
> *• Source entities outside of the ARIN region must ...*
> *• Source entities within the ARIN region must ….*
> • The conditions on a recipient outside of the ARIN region will be ...
> • Recipients within the ARIN region must …
>
> Such clarity helps insure that there is complete understanding of the
> policy intent and any conditions that ARIN might need to consider during
> its review.  ARIN does not ever require any particular language, but
> clearer policy language makes for faster and more accurate reviews of
> compatibility with our InterRIR transfer policy requirements.
>
> Best wishes,
> /John
>
> John Curran
> President and CEO
> American Registry for Internet Numbers
>
>
>
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