I have a government agency client with a number of /24s that they acquired back in the 1990s when they operated as an ISP for other agencies. They are interested in renting or selling these addresses. Are there any existing ARIN or other legal restrictions against government organizations doing this?
-mel beckman
Hi Mel,
The agency may follow the same "specified transfer" process as
everyone else to sell the addresses. See ARIN NRPM section 8.5.
There's probably a legal mess around a government entity renting IP
addresses. If the entity is registered as an end user (instead of as
an ISP) then such rentals might also be considered fraudulent.
Regards,
Bill Herrin
There's probably a legal mess around a government entity renting IP
addresses. If the entity is registered as an end user (instead of as
an ISP) then such rentals might also be considered fraudulent.
On a purely pragmatic level, it's also an exceedingly bad idea to let
a private party who may turn out to be a criminal use IP addresses
authentically registered to your government agency to commit crimes.
As an end-user, you won't be able to SWIP information about the
rental, leading angry law enforcement offers to knock upon your door.
Regards,
Bill Herrin
Or they're the perfect set of addresses to use for criminal purposes.
~Seth
Bill,
Is there a technically a restriction preventing swiping of this IP space when it's being rented? How is that different from an ISP swiping its customers that are renting bandwidth?
-mel via cell
Hi Mel,
You'd have to ask ARIN to be sure, but I beleive they only accept
SWIPs for ISP registrants. Nothing stops the agency from
re-registering as an ISP (ARIN will accept you as an ISP if you want
to be) but it means new signing new documents (which may be a problem
with your legal dept) and possibly paying more money each year.
Regards,
Bill Herrin
Simple to check. Most likely legacy space if early 90s. Enter them in the
ARIN search box and learn more. And note if the agency is paying arin
annually? Possible?
Thank You
Bob Evans
CTO
Bill,
Is there a technically a restriction preventing swiping of this IP space when it's being rented? How is that different from an ISP swiping its customers that are renting bandwidth?
This is a difference between an "Allocated" block of addresses to an
ISP and an "Assigned" network prefix belonging to a end-user.
End-User Orgs typically lack technical ability to create re-assignment
records showing a different
organization, b/c they have IPs assigned for a specific network....
ISPs / Co-location providers who are ARIN members with Allocated addresses
can Re-Allocate to a downstream ISP or Assign a network prefix from allocated
space to a downstream End-user organization.
An End user can likely show they're an ISP, join ARIN as an ISP member, &
request Direct Assignments from ARIN be combined into new Allocations;
If the character of the network changes, I would expect the new ISP
may have to show information to ARIN establishing that the change to
an ISP Allocation will be consistent with the NRPM requirements.....
(Seeing as Assignments to End-Users and Allocations to ISPs have
different policies for creation described in the NRPM, and there's
no mention in the Policy they can be directly converted without a
Transfer or Renumber/Consolidate or Return & renumber....)
This agency already is an ISP - they started out as an ISP for other government agencies. But I'll verify their ARIN records to be sure ARIN sees it that way, since they launched as an ISP back in the 1990s.
-mel
Their space is legacy, and they don't pay ARIN. They declined the offer to pay ARIN some time ago 
-mel
Jimmy,
Their ARIN record says Direct Assignment rather than Direct Allocation, so it does appear ARIN considers them an end user. Also, I see no prior SWIPs, so possibly they never SWIPed their previous customers. I'll have to give ARIN a call.
-mel
Ah, well good news and bad news.
The good news is that they can do whatever they want with their space
except make ARIN recognize a transfer. They are under no contractual or
legal obligations to ARIN whatsoever.
To transfer the block, the buyer will have to jump through all of ARIN's
hoops after which your agency can sign an LRSA for the block to be sold
just long enough to sell and transfer it (ending the LRSA contract).
The bad news is that unless they become an ARIN ISP, pay up and sign
contracts agreeing to obey ARIN's ISP rules, the whois information for any
rented address blocks will continue to lead right back to them. That will
make renting to private organizations challenging.
Regards,
Bill Herrin
Mel -
US Government agencies should contact GSA (or DoD/DISA, for those in military/intelligence communities) for advice on these matters.
Thanks,
/John
John Curran
President and CEO
ARIN
John,
It's a California State government agency. Does that make a difference?
-mel
Yes - very much so. (US Government has interesting procedures stemming
from the US Constitution for handling the release of any rights or interest,
but the same does not apply to state governments.)
Mr. Herrin’s remarks are correct - normal ARIN transfer procedures apply.
Thanks,
/John
John Curran
President and CEO
ARIN