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

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

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