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

[John Curran]

On Oct 9, 2013, at 2:03 AM, Matthew Kaufman <matthew at matthew.at> wrote:
> On Oct 9, 2013, at 12:33 AM, Matthew Kaufman <matthew at matthew.at> wrote:
>> If I host a large computing cloud or storage cloud, I really need to be able to get additional address space as that cloud grows. There may be no addresses that are "assigned to a specific customer" or even a "pool of addresses that are used by specific customers" in the traditional ISP sense. In fact, I might consider myself an end-user of IP space, not an ISP, and be attempting to get address space as an end-user. And the growth of the exposed IP surface of that cloud may or may not be a linear function of the physical resources I throw at it. In fact, as the physical resources get more powerful, I would expect not.
> ...
> And under the proposed policy your usage verification would require "a plurality of new resources requested from ARIN must be justified by technical infrastructure or customers located within the ARIN service region"... and so if you don't count my virtual servers as "technical infrastructure" (see your previous reply: "We don't consider virtual 'technical infrastructure' for assessing the need for addresses") and the "customers" of my cloud service happen to be mostly outside of the ARIN service region, what then?

Under the present policy, your _end-user_ request would be approved if you could
credibly shown that you have used 80% of all previously assigned address blocks. 
We have no need to consider the regional nature of the customer or equipments
usage that led to this, but do need credible evidence of the utilization.

Under the proposed policy, your _end-user_ request would be still approved if you
could credibly shown that you have used 80% of all previously assigned address 
blocks (this does not change.)  Note that we now need to credibly determine the 
regional nature of the customer or equipment growth behind that utilization.

Per your example, you've assigned a lot of IP addresses to a small amount of 
in-region equipment, and as long as that can be confirmed, your request would
be approved, _but predominantly because you are requesting an additional block
as an end-user under NRPM 4.3.6, and not an ISP requesting an additional block
under NRPM 4.2.4.  ARIN allocates blocks of IP addresses to ISPs for the purpose 
of reassigning that space to their customers, and that means the proposed policy
would significantly impact ISPs who assigned IP addresses to customers out of 
region.

This is the correct result, as the draft policy adds the consideration of the 
service region of the customers or equipment as a criteria, but otherwise does 
not change how ARIN presently considers customer growth or equipment growth 
in verification of requests under ISP or end-user policies.  It is the nature 
of ARIN's policies for ISPs which require consideration of the customers, and
under the proposed policy, customer location. 

Note you failed to include my complete quote in your reference above, it was:

>>> "We don't consider virtual "technical infrastructure" for assessing the need for addresses, _even though service providers may use such when adding customers._"

Per NRPM 4.2, requests for address space _from an ISP_ is justified based on
customer growth. Your example above is, per your own words, and end-user 
request and hence my quote on service providers is not applicable.

Today, customer and equipment growth outside the region qualifies today for
determining utilization and would not qualify under the proposed policy. The
proposed policy does not change the handling of virtual infrastructure, and
ISP requests will still need to be backed by customer growth in any case. 

Thanks!
/John

John Curran
President and CEO
ARIN