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

[Milton L Mueller]

Wow. This is a brilliant proposal that squarely faces problems that are at the core of many institutional issues related to address allocation. It may, however, be a step or two ahead of its time. My concern is that there may need to be preparatory steps taken regarding the exclusivity/shared status of the Whois directory information. See this for more info: http://blog.internetgovernance.org/blog/_archives/2011/2/12/4748945.html 

But in another sense we are facing a chicken and egg problem; until and unless this kind of a policy passes we may never be able to clarify the status of Whois. Anyway, as a directional indicator of where we need to be headed, I think this statement from prop-133 is one of the wisest, most forward-looking things I have seen in a proposed ARIN policy for a long, long time:

"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."



> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
> Behalf Of ARIN
> Sent: Monday, February 14, 2011 11:49 AM
> To: arin-ppml at arin.net
> Subject: [arin-ppml] ARIN-prop-133: No Volunteer Services on Behalf of
> Unaffiliated Address Blocks
> 
> 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.
> 
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> 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:
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> 
> The ARIN Policy Development Process can be found at:
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> 
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> Regards,
> 
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
> 
> 
> ## * ##
> 
> 
> 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
> 
> 
> 
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