[arin-ppml] ARIN-prop-133: No Volunteer Services on Behalf of Unaffiliated Address Blocks

[ARIN]

ARIN received the following policy proposal and is posting it to the
Public Policy Mailing List (PPML) in accordance with the Policy
Development Process.

The ARIN Advisory Council (AC) will review the proposal at their next
regularly scheduled meeting (if the period before the next regularly
scheduled meeting is less than 10 days, then the period may be extended
to the subsequent regularly scheduled meeting). The AC will decide how
to utilize the proposal and announce the decision to the PPML.

The AC invites everyone to comment on the proposal on the PPML,
particularly their support or non-support and the reasoning
behind their opinion. Such participation contributes to a thorough
vetting and provides important guidance to the AC in their deliberations.

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

The ARIN Policy Development Process can be found at:
https://www.arin.net/policy/pdp.html

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Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


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ARIN-prop-133: No Volunteer Services on Behalf of Unaffiliated Address
Blocks

Proposal Originator: Benson Schliesser

Proposal Version: 1

Date: 13 February 2011

Proposal type: New

Policy term: Permanent

Policy statement:

Add the following to the NRPM:

13.  Unaffiliated Address Blocks

13.1. No Volunteer Services

Except in the specific circumstances described by this policy, ARIN will
not provide any services for any organization and/or address block. This
includes without limitation all directory services, reverse mapping
services, and future services that may be provided to the community.

13.1.1.  Requested Services

In the event that an organization explicitly requests registry services
from ARIN for one or more specified address blocks, ARIN may provide the
requested services, subsequent to execution of a service contract, for
those address blocks. This includes without limitation all directory
services, reverse mapping services, and future services that may be
provided to the community.

All address blocks that are assigned or allocated by ARIN under a valid
RSA, as well as specific address blocks that are included under a Legacy
RSA with the legitimate validated address holder, are deemed to have
services requested for them.

An organization requesting registry services for one or more specified
address blocks, that also holds additional address blocks not specified
in their request, is not obligated to receive registry services for
those additional address blocks and those blocks are not deemed to have
services requested for them.

13.1.2. Directory Placeholders

For any address blocks, for which there are not fully executed ARIN
service contracts, ARIN will create generic placeholder entries in the
ARIN Whois directory.  These placeholder entries will not specify
organizational details, but will indicate that the entry represents a
non-member resource.

When applicable, each non-member resource placeholder will include a
reference and/or RWhois referral to the authoritative directory service
for that block, or the directory service operated by the IANA, or by
another organization in the event that IANA has delegated their
directory service responsibility to that organization.  This does not
apply to placeholders that represent an unassigned and unallocated
address block delegated to ARIN by the IANA.

13.2. Recognition of Legitimate Address Holders

ARIN will use the following criteria in order to determine whether an
organization is the legitimate address holder for a given IP address block.

13.2.1. Original Allocation Record

The original allocation records, such as those documented in RFC 1166
issued in July of 1990 or the InterNIC database received by ARIN from
Network Solutions in December of 1997, will be used as dispositive
proof, absent any contrary documentation such as those specified in
section 13.2.4 below, in determining whether an organization is the
legitimate address holder.

13.2.2 IANA Records of Legitimate Address Holders

In the event that the IANA has historical records, and/or current
records, showing the assignment or allocation of a given IP address
block to a specific organization, those records will be used as proof,
absent any contrary documentation, in determining whether an
organization is the legitimate address holder.

Further, in the event that this evidence conflicts with any evidence
from the original allocation records, or any contrary documentation such
as those specified in section 13.2.4 below, the evidence from the
original allocation record will take precedence.

13.2.3. Records Maintained on Behalf of the IANA

In the event that the IANA has delegated responsibility for the
management of an address block to another organization, including ARIN
or any other RIR, and that organization has historical and/or current
records showing the assignment or allocation of a given IP address block
to a specific organization, those records will be used as evidence in
determining whether an organization is the legitimate address holder.

Further, in the event that this evidence conflicts with any evidence
from the original allocation records, or any contrary documentation such
as those specified in section 13.2.4 below, the evidence from the
original allocation record will take precedence.

13.2.4. Formal Records Clarifying the Chain of Custody

In the event that formal records, such as public records or other formal
documents which can be authenticated or verified to include legal,
financial, and other organizational documentation, are provided to ARIN
by an organization seeking recognition of their status as the legitimate
address holder, then ARIN will consider the impact of these records as
potentially updating any evidence that may exist.  If these records
clearly document the assignment or allocation of a given IP address
block to a specific organization by direct assignment, and/or
organizational transitions such as mergers, acquisitions, business unit
restructuring, asset transfers, name changes, and so forth, absent
definitive documentation to the contrary, then these records will
determine whether an organization is the legitimate address holder.

13.3.  Permitted Updates to Directory Services for Unaffiliated Address
Blocks

Any organization that legitimately holds an address block, as defined by
section 13.2 of this policy, may request the removal or modification of
existing directory placeholders representing that address block.

Valid requests for modification of placeholder entries are limited to
references and/or RWhois referrals to authoritative directory services,
such as directory services operated by or on behalf of the IANA, another
address registry, or the address holder.  In the event that such a
request is received, ARIN may choose to either remove the placeholder
entry or update it per the request.


Rationale:

Policy Background:

This policy attempts to clarify the relationship that ARIN has with
legacy address holders.

Specifically, this policy recognizes that absent an agreement such as
the RSA or LRSA there is no formal relationship with legacy address
holders.  At present, however, ARIN continues to provide services to
these organizations.  This is done without compensation and potentially
in opposition to the legacy address holders' wishes.  As a result of
this behavior ARIN has created an illusion of implied authority that
exposes ARIN to unacceptable levels of liability, is hindering the
development of an open address market (driving it "underground"), and is
putting the operational stability of the Internet at risk.  As new
services such as RPKI are contemplated this situation becomes even more
critical.

This policy would require positive affirmation from any legacy address
holder that wishes to receive registry services, moving to an "opt-in"
approach.  In the event that a legacy address holder does not opt-in to
receive registry services, ARIN is limited to providing no more than a
pointer (such as a RWhois referral) to an authoritative directory
service for that holder's legacy address blocks.  Pointers to other
providers of directory services for addresses managed by those
other providers continue to be permitted.

Policy Structure:

This policy introduces a new section to the NRPM, numbered section 13.
Within this new section, there are three sub-sections.

Sub-section 13.1 introduces policy that limits ARIN to providing
services on an opt-in basis.  It does make clear in 13.1.1 that services
provided as part of a RSA or LRSA are automatically considered opted-in.
  With 13.1.2 it allows ARIN to create placeholders in the Whois
database for blocks managed by other RIRs as well as for blocks managed
(but unassigned/unallocated) by ARIN.

Sub-section 13.2 introduces policy that specifies how ARIN will go about
determining who a "legitimate" address holder is.  It is similar to
current procedure with 13.2.2 and 13.2.3, which specify the use of IANA
and RIR records.  It expands on the current procedures with 13.2.4,
allowing organizations to provide legal documentation of organizational
changes and/or the transfer of custody of a legacy address block.

Sub-section 13.3 introduces policy enabling legitimate address holders
to request a very limited update to any Whois placeholders that might
exist for their legacy address block, so that the Whois will refer
queries to the authoritative directory service.  It is expected that
ARIN will charge a fee for this update, but not require an ongoing
services agreement.  ARIN is given the option of deleting placeholders
instead.

Timetable for implementation:  Immediately