[arin-ppml] ARIN actions regarding address blocks with no valid POCs (was: Re: Deceased Companies?)

[Paul E McNary]

If I understood what John clarified for me earlier in this thread ...
Many of the Legacy blocks will not be under NPRM and ARIN has to tread very carefully on trying to claw these addresses back.
Many blocks that might be abandoned fall into legacy, especially /24's, assigned pre-ARIN.
As always, many times I understand incorrectly.

----- Original Message -----
From: "Ted Mittelstaedt" <tedm at ipinc.net>
To: "John Curran" <jcurran at arin.net>
Cc: "arin-ppml" <arin-ppml at arin.net>
Sent: Thursday, August 4, 2022 9:30:36 PM
Subject: Re: [arin-ppml] ARIN actions regarding address blocks with no valid POCs (was: Re: Deceased Companies?)

> Ted -
> 
> To my knowledge, the Number Resource Policy Manual (NRPM, i.e. 
> https://www.arin.net/participate/policy/nrpm/ 
> <https://www.arin.net/participate/policy/nrpm/> ) does not presently 
> provide for ARIN performing reclamation of address blocks assigned to an 
> organization that has no valid POCs – it provides that such 
> organizations "will be unable to access further functionalities within 
> ARIN Online” and cannot be receiving organization for a reallocation or 
> detailed reassignment. (NRPM 3.6.5 and NRPM 3.7 respectively)
>

Technically an org like LT is obtaining a detailed reassignment from
whatever ISP they are using (most likely, it's a /29)   Of course, they
probably don't even realize or remember that they have a prior 
allocation which according to the NRPM needs valid POCs and also needs 
to meet utilization requirements before they were supposed to get their /29

But, like I said, they aren't bad people, just likely ignorant of what
they have.  I suspect ARIN could take care of this by directly 
contacting them based on 3.6.5 and 3.7.  I also suspect that is the case 
for a lot of the abandoned stuff.  I do agree it would take a LOT of 
manpower and lacking clear direction from the community to do it is
probably a big sticking point for ARIN which is why you are hinting a
policy change is needed.

> If you’d like ARIN to take particular action on address blocks with no 
> valid POCs, please propose policy specifying the actions for community 
> consideration and potential adoption.
As you know, the main reason the POC validation was put into NRPM was to 
allow ARIN to require POC validity, so that it would discourage spammers 
and other criminals from trying to hide themselves behind fake names if
they registered blocks, and it would make it possible to alert block
holders who had bad citizens acting from IPs in their blocks.

It was the "license plate" argument, that is, just like a car they are
using a public resource, so the public has a right to know who they are,
which is why we slap license plates on cars.  Even though that really
pisses off some people.

But a secondary reason was to try to get a handle (no pun intended) on
the extent of the "abandoned resources" problem.  Along with validation 
came a requirement for ARIN to report.   Well, it's certainly been long
enough to get some valid data back - could you, John, say now, based on
that data, what percentage of IPv4 number resources in ARIN are like 
this particular one - they have only invalid POCs and no valid ones?

While those resources might not be available for use  (as their orgs 
might be using them internally and just not kept up with the reporting 
requirements) if you could give us a percentage, if it's high enough
it might stimulate the community to support additional requirements for
having ARIN get a bit more activist on getting these resources back.

I sort of liken this to the "abandoned car" issue in a major city.  If
the numbers of abandoned vehicles in a city are below .0001% then the
population does nothing, but if it increases to .01% or .1% the 
population goes ballistic and starts demanding the city start towing,
because the public wants it's street parking space back.

So the question is, what are we leaving on the table?  I think that was
the thrust behind the very first query on this thread.

Frankly I DO think we should seriously consider revoking registrations 
of number blocks that lack valid POCs.  In this day and age, asking a 
number block holder to supply a valid POC is the absolute LEAST that the 
community can ask.  It's not enough to have just a valid street address. 
  It is after all, year 2022.  Having an email address is NOT a barrier 
to anyone.  If they are a small org they can just duplicate most of the 
info in the main number block into a POC and add a phone number and 
email address.  It's not a hardship.  If they are large then a street
address of some main corporate HQ is useless if anyone needs to contact
an individual about something going on from their IP addresses.

Ted

>   You can find more information on 
> submission of policy proposals here - 
> https://www.arin.net/participate/policy/pdp/appendix_b/ 
> <https://www.arin.net/participate/policy/pdp/appendix_b/>
> 
> Thanks!
> /John
> 
> John Curran
> President and CEO
> American Registry for Internet Numbers
> 
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