[arin-ppml] Unreachable address blocks (was: Re: Have we REALLY got to this sad state of disrepair?)

Tue Apr 12 19:33:00 EDT 2022

Folks -

Let’s try to untangle this a bit…  The problem that we are discussing is predominantly with regard to legacy number resources, and in particular legacy number resources that have not been put under a registration services agreement with ARIN.

The reason for this is quite simple: legacy resource holders not under contract are receiving ARIN's basic registry services without any annual fee to be paid. Those who pay an annual registry maintenance fee to ARIN are much more reachable (generally good contacts and a known organization), and should they “disappear”, the bills stop being paid, and the resources get recovered (and will end up being issued on via the Waiting List Policy - such as occurred earlier today - https://www.arin.net/announcements/20220412/)

Regarding the legacy resource holders who haven’t signed a registry services agreement, ARIN needs to exercise significant caution – but that has little to do with authority of ARIN over the registry or ability to enforce registry policy.   It’s much more basic than that - legacy resource holders received their blocks from parties who were issuing them pursuant to agreements with the US Government to do so, and under circumstances where the corresponding responsibilities were not clearly spelt out.  While responsibility for administration of the number resources has passed to ARIN, that doesn’t mean that any given legacy resource holder is aware of such a change, is aware that this community would expect good contact information to be maintained, or is aware of any other obligations that may get put into registry policy.

Making things even more exciting is that, while many of those with legacy address blocks obtained them “to connect to the Internet”, that is neither uniform nor is it clear that such was ever intended as requirement – so a legacy address holder who was issued a block, and now it is using it completely “internal” and not routed to the public Internet is effectively unseen by all of us (and similarly is quite likely completely unaware of the discussion going on this mailing list, on the nanog list, etc.)

The ARIN community needs to carefully consider how it treats an organization that may be unreachable today entirely because there was never a clear expectation that the organization should be keeping their contact information in the registry up to date.  Lack of current contact information (or even lack of clear evidence that the party that was issued resources still exists) does not universally equate to “abandoned number resources” - it is quite possible that the party issued the block is simply enjoying their use of them somewhere out of sight to this community.

So:

  1.  Yes, ARIN has the authority to administer the registry in accordance with community policy, and that does include the legacy number resources.
  2.  The community could make a policy that says, “After exercising a certain level of effort to contact a resource holder, a complete lack of response shall provide ARIN a basis to recover the address block...”,  _but_
  3.  Adoption of such a policy would disregard the potential impact to those who hold legacy number resource blocks but just haven’t maintained current contact information over the last 25 years (whether for lack of effort or just not knowing that ARIN even existed, was administering the registry, or that they had the ability update their contact information all a while without any contract or fee.)

What would be really nice is if there were a group of folks who were willing to research all these legacy blocks, hunt down the resource holder for each, and encourage them to update their records at ARIN and/or perhaps even transfer the address block to someone who feels a stronger need…

As it turns out, that’s precisely what’s happening with the ARIN transfer facilitators, and as a result many of these records are getting cleaned up entirely due to the magic of market forces.   Note - I am not saying that either of "there is a need” or “there is not a need” for registry policy regarding unreachable or “zombie” address blocks - that is ultimately for the community discuss and decide – but wanted to make sure that full context is available about what particular address blocks we’re likely referring to, and to try and share the view of at least some of those with resources who may be affected by any policy in this area.

Thanks!
/John

John Curran
President and CEO
American Registry for Internet Numbers

On 12 Apr 2022, at 5:51 PM, Adam Thompson <athompson at merlin.mb.ca<mailto:athompson at merlin.mb.ca>> wrote:

You'd think so!  But there's some complication because it's a legacy allocation, and thus not (yet) legally under ARIN's control/jurisdiction, or something along those lines.  I don't remember the exact details, sorry.  I'm sure if I explained it incorrectly-enough someone here will correct me in the near future ;-).
-Adam

Adam Thompson
Consultant, Infrastructure Services
MERLIN
100 - 135 Innovation Drive
Winnipeg, MB, R3T 6A8
(204) 977-6824 or 1-800-430-6404 (MB only)
athompson at merlin.mb.ca<mailto:athompson at merlin.mb.ca>
www.merlin.mb.ca

-----Original Message-----
From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Fernando
Frediani
Sent: Tuesday, April 12, 2022 4:38 PM
To: arin-ppml at arin.net
Subject: Re: [arin-ppml] Have we REALLY got to this sad state of disrepair?

Is it necessary for a third party to have to prove that categorically ?

My understanding is that it should be enough to send fair amount of
evidences to the RIR and it has the duty to get in touch with that
organization to gather information and if necessary ask them to justify
if the justifications given in the past remain valid (if there is any
response), and if not then simply recover the block, isn't it ? That
should be that natural path for these things to happen.
If a block is abandoned for a long time, there is no response for the
said resources holder then recover it and assign to someone else that
really justify for that now a days.

Fernando

On 12/04/2022 18:32, Adam Thompson wrote:
I would like a mechanism to do this, or something closely related -
nominate blocks we know are orphans.  For example, I obtained a legacy
/24 for my employer in the early '90s.  That company is no longer in
business.  I can guarantee the block isn't (or shouldn't be) in use on the
public internet.  I know the owner never sold it, because I was working with
him on that.  But I have no way to *prove* its abandonment.  So there it
sits, forever inaccessible.  I mean, I could squat on it :-) but that's called
"being part of the problem".
The amount of effort it was going to require on my part and the company
owner's just to get it released back into the free pool, never mind sell it, was
prohibitive.  (I've had this discussion with Cathy(?) @ Member Services
before, getting things notarized in Manitoba is a VERY significant burden, in
time, in travel, and in cost, compared to other jurisdictions.)
There really ought to be a better solution to that - everyone on this list is
probably aware of some zombie/orphan allocations they've been involved
with.
Within ARIN's current stance/perspective on legal issues (which I've
criticized before, here), though, I don't see any easy fix.
-Adam

Adam Thompson
Consultant, Infrastructure Services
MERLIN
100 - 135 Innovation Drive
Winnipeg, MB, R3T 6A8
(204) 977-6824 or 1-800-430-6404 (MB only)
athompson at merlin.mb.ca
www.merlin.mb.ca

-----Original Message-----
From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of William
Herrin
Sent: Monday, April 11, 2022 8:55 PM
To: Ted Mittelstaedt <tedm at ipinc.net>
Cc: arin-ppml at arin.net
Subject: Re: [arin-ppml] Have we REALLY got to this sad state of
disrepair?

On Mon, Apr 11, 2022 at 5:00 PM Ted Mittelstaedt <tedm at ipinc.net>
wrote:
ARIN has been pussyfooting around long enough with these zombie
resources, by now CKN23-ARIN should NEVER appear tied to a number
resource.  Please, get on the stick and get these resources freed so
they can be used.
Hi Ted,

I look forward to your policy proposal in which an IP broker or other
interested party can be granted care of a zombie legacy block, perform
the legal diligence needed to justify releasing its registration,
arrange the proper indemnity for ARIN should they have it wrong, and
subsequently arrange its transfer to a new registrant.

There are, of course, no non-legacy zombie blocks. The non-legacy
blocks unavailable for assignment are in cool-down which is a
different thing entirely.

Regards,
Bill Herrin

--
William Herrin
bill at herrin.us
https://bill.herrin.us/
_______________________________________________
ARIN-PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
Unsubscribe or manage your mailing list subscription at:
https://lists.arin.net/mailman/listinfo/arin-ppml
Please contact info at arin.net if you experience any issues.
_______________________________________________
ARIN-PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
Unsubscribe or manage your mailing list subscription at:
https://lists.arin.net/mailman/listinfo/arin-ppml
Please contact info at arin.net if you experience any issues.
_______________________________________________
ARIN-PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
Unsubscribe or manage your mailing list subscription at:
https://lists.arin.net/mailman/listinfo/arin-ppml
Please contact info at arin.net if you experience any issues.
_______________________________________________
ARIN-PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
Unsubscribe or manage your mailing list subscription at:
https://lists.arin.net/mailman/listinfo/arin-ppml
Please contact info at arin.net if you experience any issues.

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-ppml/attachments/20220412/2c0217f5/attachment.htm>