For what it is worth...
I must say I sympathize with Kai. While it looks like our clients may come out ok in all this (I hope), we have had similar problems trying to grow and operate as a small niche provider. It all seems to stem from the understandable fact that the larger providers are trying to look out for the interests of Internet as a whole as well as themselves. If the small niche providers suffer it may, or may not, be a small price to pay. However, I feel (granted I'm biased) that a competitive market place which allows small niche providers to compete will benefit the Internet in the long run.
A few months ago we went looking for a /18 from the Internic for reassignment to our clients. After about a month of discussion with the Internic, we were unequivocally told we had to make due with a /19. A /19 was all we could justify, and we do understand the need for such justifications - we needed to show that we could make good use of the /19 before they would consider talking with us further on the issue. Furthermore, we had to make a decision or stop taking on new customers at that point, so we took the /19 from the Internic and went ahead with business.
We went to the Internic looking for an /18 allocation instead of Sprint or MCI for a handfull of reasons, including:
[...]
2) While we could only justify a /19, we were rather worried about what was going to happen with the /19's. ...
3) Being multi-homed, it seemed to make sense to announce an independent address blocks so as to avoid whatever complications that might arise in the future from the announcing of address blocks belonging to one provider into another provider at our level.
So now Sprint went ahead and filtered our /19 as they hear it from MCI.
[...]
Going forward, my concern arises because it is not clear to me how a policy which only enables organizations able to justify /18 portable independent allocations for reassignment (at the moment I don't believe you can even buy your way into such an assignment) will provide a competitive environment which includes small niche providers. I don't think an environment which locks small players into a supplier is competitive from anyones vantage point. Maybe I'm missing something, maybe all this is being taken care of as I write this (I did see some good suggestions floating around), or maybe the Internet would be better off without all the small niche providers.
The solution to this is to make sure the registries have space to use for portable slow-start assignments. If registries are running out of such space and are running into the /18 limits from 206 on up, then we need to agree to set aside pools of addresses for slow-start assignments where there are no /18 restrictions. This is a bit problematic, but it has to happen. Additionally, registries need to make sure their slow-start assignment policies are adequate and ramp up as needed. [I used to work for an ISP that got allocations in the following order: /21, /20, /19, /16 ...; this is adequate, and this ISP is using its address space efficiently and quickly; pretty soon the number of customers with addresses from the long prefixes will be small compared with the others, and coordinating a renumbering effort should not be too hard]. Additionally, registries need more resourcings to check applicant's claims. A growing ISP that can demonstrate its rate of growth and rate of utilization of already delegated space should have no problem obtaining /18s and eventually /16s and /14s without having to suffer very long through using /19s and smaller. This can be accomplished by fees, not for the IP space, but for the investigation efforts. Consider that there are several types of people and organizations that go to registries for IP address space. To some of these (niche/regional/growing ISPs, the size of delegations has an enormous impact on their business viability. If a registries' actions or lack thereof hurt someone else's business they may end up being liable in court for it (same goes for providers, which act as registries for their own address space). Even if law never entered the picture, it is very important that lack of resources or organization not end up slowing growth of the Internet. So, please, I urge registries to consider charging for their address space delegation services, just as they are now breaking ground with domain name registration fees. If registries can make decent allocation decisions wrt deserving applicants, while witholding services from un-cooperative applicants (who often make fraudulent claims), then I argue that routing table growth will be curbed and that IPv4 address space utilization effeciency will rise. But the registries must get good first, which is nearly impossible under the strains of limited budgets and exponential growth in demand.
My hope is that those parties who do influence policy creation will leave room for small niche players players to compete when they do come to agreement on this and future issues.
Large NSPs like Sprint et al. have to be careful, if the situation degenerates to a point where it becomes very hard for new players to enter the market in a good position, then their actions may end up being construed as collusion and price-fixing. The result is lawsuits. For what it matters, I support the /18 model, but I urge the creation of pools of space for slow-start registry delegation policies; if the large NSPs that are pushing the /18 model make room for slow-start delegation policies to continue to be viable, then they can avoid collusion charges, therefore it should be in their best interests to reach a good solution to problems like yours.
Also I hope that those same parties are cognizant of the fact that actions they take to further their goals can have a serious impact the small players out there. All this being a case in point. While a little bit of incoming filtering by Sprint may have next to no impact on the ability of Sprint to do business, it could devastate a small niche provider someplace who has to say to their clients, "Sorry, we are only able to provide you with partial Internet service at the moment because Sprint doesn't like the addresses we assigned you".
It is costly, as the solution is to become a client of Sprint. So, everyone, can we find a solution?
Now that I've had my say, I'm going back to the sideline.
John Riordan Vice President Interport Communications Corp. 1133 Broadway New York, NY 10010 212-989-1128
Nick