[arin-ppml] Draft Policy 2010-10 (Global Proposal):GlobalPolicy for IPv4 Allocations by the IANA Post Exhaustion- Last Call (textrevised)

[Stephen Sprunk]

On 02 Nov 2010 22:30, Ted Mittelstaedt wrote:
> On 11/2/2010 5:38 PM, Bill Darte wrote:
>> Never, in my memory, has the debate over recovery of legacy addresses
>> been given more than superficial treatment.
>>
>
> I think that this is because ultimately the goal isn't to take legacy
> resources away that are IN USE.

IMHO, that depends on the degree of non-compliance.  I've worked with
dozens of orgs with legacy space, and not a single one of them could
even come close to justifying their space _that was in use_.

However, I don't see any point in targeting orgs using their space
inefficiently until we've dealt with all the ones (and I really do mean
every last one that can be found) not using their space _at all_.

> Ultimately the goal should be to take legacy resources away that are
> either being hoarded, or are abandoned.

"Hoarded" is a loaded term, and it's difficult to prove someone's doing
it.  "Justified" is easily determined, though, since we _already_ have
dozens of pages of policy describing exactly what that means.

>> Seems that the typical statements that stop debate is that such a
>> course would be prohibitively expensive from a legal point of view
>
> Rubbish.  If ARIN takes over an abandoned Legacy resource then since
> it is abandoned, the original org that had it cannot suffer damages,
> and since it hasn't suffered damages, it has no standing to sue in court.
>
> The problem is that since the original Legacy holder did NOT ever sign
> an agreement with ARIN then ARIN has no contractual justification to
> take over an abandoned Legacy assignment even if they know it's unused,

AFAICT, if the registrant does not have a contract (i.e. RSA or LRSA)
with ARIN for registry services, ARIN has no obligation to continue
providing them, especially for free.  There are many who feel ARIN has a
_moral_ obligation to do so, but that's not a matter for the courts.

> because so far the community has not given ARIN permission to do this
> via policy in the NRPM.

That all depends on how one interprets NRPM 12.8.

IMHO, ARIN _already_ had the power to apply policy to legacy space or
revoke it entirely, and therefore NRPM 12 actually _limits_ how ARIN may
do so, as it does for non-legacy resources.

> Right now, Legacy netblocks that are attached to POCs that ARIN
> determines are non-respondent, can ultimately be freed up.  All ARIN
> has to do is determine a POC is abandoned and when ALL POCs that are
> on a particular Legacy block change to abandoned status, then the
> resource is, (in my opinion) effectively freed, and (in my opinion)
> ARIN should move it back into the free pool of assignable IPv4

Wrong.  ARIN would need to follow the procedure in NRPM 12, which
governs _all_ reclamation activities.

However, if all the POCs are unresponsive, then presumably they will not
respond with justification as required in 12.1, they will not
voluntarily return the resource(s) as required in 12.4, and eventually
ARIN can revoke the resource(s) under 12.5.

>
> But that does not answer the Legacy space that is unused, yet still
> has a respondent POC on it.  Or Legacy space that the master block
> has an abandoned POC but has active POC's that are in SWIPS that
> were filed on parts of it.

One can address most of those by having other processes that add to the
same list of resources to be reviewed.  For instance, one might consider
a resource not appearing in the DFZ to be a sign of probable
non-compliance which triggers a review.  Or resources which have not
been updated in the last N years.  Or not having valid rDNS servers.  If
the review concludes they're valid, the registrant has 24 months before
they have to worry about being hassled again.

Yes, a sufficiently cagey registrant may be able to avoid all of our
heuristics, but most won't even try to.  It's reasonable to lose a
battle to a skilled and dedicated opponent; it's absolutely indefensible
to surrender a battle when your opponent doesn't even show up, which is
where we are right now.  Let's fix the latter problem before we worry
about the former.

> And on top of that, not too long ago I thought the AC stated they
> would no longer entertain drafts of policy changes that dealt entirely
> with IPv4.  So please don't duck behind this "if you think you have a
> better method then make a proposal" bullcrap.

Most of the problems with legacy IPv4 blocks also apply to legacy ASNs,
so proposals along these lines need to say "resources" anyway.

> There are too many people now in the ARIN community that just want to
> bury IPv4 and really aren't interested in mining possibly usable IPv4
> from Legacy resources.  They want to believe if we just ignore it we
> can leave IPv4 behind in a few years and switch everything to IPv6 and
> they won't believe this isn't going to happen right away until it just
> doesn't happen right away.  Maybe they are right.  I just hope that if
> they are not, that they start mining.

I don't think that "mining" IPv4 blocks for reclamation will have any
meaningful effect on runout, but I still think it's worthwhile for
several other reasons.

S

-- 
Stephen Sprunk         "God does not play dice."  --Albert Einstein
CCIE #3723         "God is an inveterate gambler, and He throws the
K5SSS        dice at every possible opportunity." --Stephen Hawking


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