[arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4 and IPv6 Address Space to Out-of-region Requestors - Revised

Tue Oct 8 23:03:07 EDT 2013

John:

It seems the ARIN staff has taken a "virtualized
hosts/devices/infrastructure don't count" approach.  I understand ARIN
staff's concern about potential abuse by some folk who may spin up a bunch
of virtualized servers to get some address space, and then use that address
space anywhere in the world and/or in a way that wouldn't have met the
NPRM's criteria, but it seems that ARIN's brush is a bit too broad.

As others have pointed out at the PPC and in this discussion, virtualization
is here to stay, and it doesn't make sense that ARIN staff's practices don't
line up with reality if the NPRM doesn't preclude that.  The NPRM only talks
about hosts, devices, and infrastructure.  I don't believe there is anything
that requires a physical host or physical infrastructure (i.e. load
balancer).  Rather than disallow virtualized hosts or infrastructure from
contributing to a host count, why not require the requestor to provide some
documentation of the validity of these virtualized hosts, perhaps through
invoices showing that Customer A had an average of 30 servers and a peak of
45 servers in the last month, Customer B had an average of 10 servers and a
peak of 50 servers in the last month, etc, and then some aggregate data that
shows many virtualized servers operated on average and at peak.  It seems
that in general the community trusts ARIN staff to sniff out abuse - and if
initially the requestors are required to show the last 3 or 6 or 9 months of
invoices or virtualization data, that's a lot better than the current
practice of not being willing to count them at all.  

And just to state my understanding of current practice, the use of
virtualization isn't a major factor in current practice if the customers are
predominately in the USA, but the concern is if the virtualization hoster
has many out-of-region customers.

Regards,

Frank

From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
Behalf Of Victor Kuarsingh
Sent: Tuesday, October 08, 2013 12:46 PM
To: Owen DeLong
Cc: John Curran; arin-ppml at arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2013-6: Allocation of IPv4 and
IPv6 Address Space to Out-of-region Requestors - Revised

Owen, all,

I am in agreement, in general, with text that takes that form if this would
cover the cases where the use of the addresses would be used on an
interfaces, servers, VMs or other elements which are built upon equipment
which is present in the ARIN region.

regards,

Victor K 

On Tue, Oct 8, 2013 at 1:06 PM, Owen DeLong <owen at delong.com
<mailto:owen at delong.com> > wrote:

Perhaps replacing "technical infrastructure" with "addresses assigned
to equipment and/or interfaces physically present within the ARIN region".

Owen

On Oct 7, 2013, at 8:37 AM, John Curran <jcurran at arin.net
<mailto:jcurran at arin.net> > wrote:

> On Oct 6, 2013, at 3:22 PM, William Herrin <bill at herrin.us
<mailto:bill at herrin.us> > wrote:
>
>> There is a subtlety here that is escaping me. If the addresses are
>> assigned to hosted infrastructure within the region then how are they
>> not used within the region?
>
> Bill -
>
> Apologies in advance for length - the community is entitled to a complete
> understanding of how we administer number resources, and that appears to
> take more words than I expected at first..
>
> Technical infrastructure can be used to justify addresses (for example,
> network routers, POP equipment, concentrators, management systems, IT
> systems, data center servers, etc.)  We're very experienced with this,
> and often ask for equipment lists, invoices, etc. to confirm existence
> of the asserted equipment.
>
> When technical infrastructure grows, more IP addresses are needed for
> assignment to the technical infrastructure. Technical infrastructure
> exists in a region based on the location of the physical devices.
>
> Customers growth can also justify addresses (e.g. you assign addresses to
> an single customer, or customer growth requires that a certain dynamic
pool
> assigned to customers be expanded)  We are also quite experienced with the
> verification of customers, including obtaining customer lists, contact
info,
> etc.
>
> When the number of customers served grows, more IP addresses are needed to
> assign to the new customers, or to assign to the dynamic pools for those
> customers.  Customers exist in a region, based on their actual location of
> each customer.
>
> For example, if someone needs more addresses because they are adding
> new VPN concentrators (i.e. more actual equipment itself), then that is
> indeed technical infrastructure need based on where the equipment will
> be installed.  i.e. if you buy stacks of new VPN concentrators and have
> no addresses to connect them to your infrastructure, it's a simple matter
> to request (per policy) additional addresses needed.  We do this all of
> the time with the infrastructure side of DSLAMS, cable head-ends, wifi
> nodes, etc.
>
> If someone needs additional addresses for their _customers_ (including
> to expand a dynamically assigned pool), then we verify the customer
> growth as noted earlier, including the location of the customers.
>
> Requesters have to show that they have additional equipment or additional
> customers to obtain addition addresses.  Both equipment and customers are
> associated with real-world addresses, and hence are within some region of
> the registry system.
>
>> What aspect of the draft policy would change that evaluation? ...
>
> The draft policy 2013-6 reads as follows:
>
> "In addition to meeting all other applicable policy requirements,
> a plurality of new resources requested from ARIN must be justified
> by technical infrastructure or customers located within the ARIN
> service region, and any located outside the region must be
> interconnected to the ARIN service region."
>
> The requesters who were previously discussed (i.e. "the 52" who have
received
> allocations since mid-year), often have some existing infrastructure, are
not
> adding anything more, and do not need more addresses due to their
_technical
> infrastructure_ growth.
>
> They do have remarkable customer growth, and hence need additional
addresses.
> Under the policy change proposed by 2013-6, we would only consider
customers
> within the ARIN service region for this purpose, and would provide an
allocation
> which they could justify based on that in-region customer demand. The
proposed
> policy change makes clear that customers must be in-region to be
considered.
> (The present policy does not have such a constraint, hence the approval of
> recent requests where the vast majority of customers are known to be
outside
> the ARIN region.)
>
> We don't consider virtual "technical infrastructure" for assessing the
need
> for addresses, even though service providers may use such when adding
customers.
> The additional customers driving such virtual growth are readily
verifiable.
> The alternative would be to consider virtual equipment (e.g. VM's) as
actual
> technical infrastructure and that would effectively open the justification
of
> unlimited resources by any party without any actual equipment or customer
growth.
>
> If the desire was to simply clarify existing policy (without actually
changing
> the current practice), it could be accomplished by dropping the "in
region"
> requirement for customers as follows: "must be justified by technical
> infrastructure within the ARIN or by customers located anywhere as long as
> the addresses are managed and interconnected in the ARIN service region."
> (Note that such a change would make rather clear that nearly any
heavily-utilized
> customer-driven IP address pool interconnected in the ARIN region can
qualify
> for additional resources, which may or may not be a desirable outcome
depending
> on one's individual perspective.)
>
> I hope this helps in clarifying what ARIN-2013-6 would be change to the
> existing policy, as it would make clear that customer growth in-region
> would be necessary to justify requests, whereas presently we have some
> folks requesting resources using nominal equipment within the region and
> backed by extensive customer growth external to the region.
>
> Please do not hesitate to ask if you have any further questions - it is
> indeed very important that folks understand how we implement the policy
> in order to fully consider any proposed policy changes, so thank you for
> your diligence on this topic.
>
> /John
>
> John Curran
> President and CEO
> ARIN
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