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[AFRINIC-rpd] Questions about IPv4 Allocation Policy AFPUB-2005-v4-001

Keshwarsingh Nadan keshwarsingh.nadan at
Wed Nov 13 09:15:51 UTC 2013

Dear Community,

I realize that this isn't the proper list for this specific question, but
since there isn't another active list to post to, I'm posting it here.

I need the authors comment as well as members.

Section 7.3 of the IPv4 Allocation Policy states the following:

In order to properly evaluate requests, an RIR must carefully examine all
relevant documentation relating to the networks in question. Such
documentation may include network engineering plans, subnetting plans,
descriptions of network topology, and descriptions of network routing plans.
All documentation should conform to a consistent standard and any estimates
and predictions that are documented must be realistic and justifiable.

Section 8.4 of the IPv4 Allocation Policy states the following:

An LIR may receive an additional allocation when about 80% of all the
address space currently allocated to it has been used in valid assignments
and/or sub-allocations. A new allocation can also be made if single
assignment or sub-allocation requires more addresses than those currently
held by the LIR.

Reservations are not considered as valid assignments or sub-allocations. It
may be useful for internal aggregation to keep some IP blocks free for
future growth. These internal reservations are however not counted as valid
usage and must be assigned or sub-allocated before requesting for an
additional allocation.

AFRINIC will always try to allocate contiguous address ranges, allowing the
LIR to minimise the number of route announcements it makes. However, it will
not always be possible to allocate a range contiguous with the LIR's
previous allocation.

Based on above sections of the policy, I, LIR-AAA needs another allocation
since I ran out of IP space for the following reasons:

a) I provide hosted services such as accounting / crm / erp on a Software as
a Service (SaaS) basis.
b) I am utilizing more than 80% of my previous allocation in valid
assignments, which is assigned to my infrastructure since the IP space is 
used to provide SaaS based service.

Business Model:

- CLIENT-BBB leases / outsources hosted service from LIR-AAA.

- CLIENT-BBB resells the leased / outsourced hosted services to their own
client, CLIENT-CCC.

- CLIENT-CCC resells the hosted services purchased from their supplier
CLIENT-BBB to their own customer base and the public in general.

For facilitating evaluation procedures, LIR-AAA exceptionally granted
AfriNIC a remote access to its infrastructure though a live remote session
since AfriNIC hostmasters primarily liaise with LIRs in the telco industry,
AfriNIC needs to fully understand:

- The business model.
- Why the service requires a whole IP space.
- How the service works.
- Peak sessions.

AfriNIC insists that in order for LIR-AAA to comply with the current policy,
AfriNIC needs to establish the existence of the end-users, i.e. CLIENT-CCC
customers. Information requested:

- Name of companies.
- Physical address.
- Contact persons.
- Email addresses.
- Phone numbers.
- Contact them if necessary.

Everyone seems to interpret the policy in his/her own way. In short:-

- Is AfriNIC allowed to request such information for evaluation purposes
according the current policy based on my business model, i.e. offering SaaS
based services?

- Is AfriNIC generally allowed to request such information for evaluation
purposes according to the current policy ?


This message is strictly personal and the opinions expressed do not
represent those of my employers, either past, present or potential future.

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