John, I would hope that if some ARIN policy is enacted there would be some way to differentiate between organizations, like the one I belong to, that have provided this kind of service to customers for a number of years and organizations looking to take advantage of the new scarcity. We have and do provide IP space for other ISPs (mainly small and mid size) despite not providing connectivity for a number of reasons. We began providing this as a way of getting connectivity provider independent space to ISPs that lacked their own ASN and usually were not multi-homed because I had so many ISPs changing their upstream provider that it was causing us issues in both our engineering and call center teams. We provide network engineering (think re-IPing lots of ISP networks) and end user technical support (think lots of calls from upset customer who had to change their static IP) for many ISPs around the country. We certainly don't have a huge allocation, we have 209 /24s reassigned and 9 reallocated currently. We also pass along all of the usage and reporting requirements that ARIN requires of us. We also don't make money on the practice we charge a small amount on an annual basis for record keeping. As I said, we started this mainly to prevent network disruption and extra work _not_ as a profit center. How a line might be drawn I don't know, but its important to understand that there are very legitimate reasons to reassign or reallocate space even if you are not providing connectivity for a given network. On 2/3/2011 11:54 AM, John Curran wrote:
On Feb 3, 2011, at 11:32 AM, Jon Lewis wrote:
My point being, the leasing of IP space to non-connectivity customers is already well established, whether it's technically permitted by the [ir]relevant RIRs. I fully expect this to continue and spread. Eventually, holders of large legacy blocks will realize they can make good money acting as an LIR, leasing portions of their unused space to people who need it and can't get it, want it and don't qualify, etc.
These start-up LIRs won't be bound by RIR policies, both because in some cases they'll be legacy space holders with no RSA with their region's RIR, and because they won't be worried about eligibility for future RIR allocations of v4 space...because there won't be any. For the ARIN region, it would be nice to know how you'd like ARIN perform in the presence of such activity ("leasing" IP addresses by ISP not providing connectivity). It's possible that such is perfectly reasonable and to simply be ignored, it's also possible that such should be considered a fraudulent transfer and the resources reclaimed. At the end of the day, the policy is set by this community, and clarity over ambiguity is very helpful.
Policy proposal process: https://www.arin.net/policy/pdp.html
Thanks! /John
John Curran President and CEO ARIN
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