[arin-ppml] ARIN actions regarding address blocks with no valid POCs (was: Re: Deceased Companies?)
Ted Mittelstaedt
tedm at ipinc.net
Sat Aug 6 16:10:28 EDT 2022
Nobody not even me is suggesting that. What I am saying is that the
ARIN community has that power.
Ted
On 8/6/2022 11:25 AM, Lee Dilkie wrote:
> The legacy blocks were created and in existence before ARIN took
> responsibility of them and while ARIN could simply take them all back,
> with no regard for history, it smacks of "colonialism" to me. You know,
> where the enlightened civilized folks take property from the savages
> because they can put it to better use. Those savages aren't even paying
> tax (arin fees) so really they should have no rights at all.
>
> See? That's how history repeats itself.
>
> -lee
>
> On 2022-08-06 11:45, Ted Mittelstaedt wrote:
>> That is correct which is why John has repeatedly stated that action on
>> these needs to originate with the community. Essentially the RIR
>> system's legal support and basis for power is the same as the United
>> Nations various subcommittees such as WIPO - general consensus among
>> members.
>>
>> ARIN is the only RIR that has legacy blocks so this is a unique issue
>> with just the ARIN RIR. Most of the rest of ARIN such as NRPM is used
>> as a pattern by the other RIRs.
>>
>> It is likely that what the community does with regards to the legacy
>> blocks will have an effect on the "deceased company" issue but the
>> simple reality with registered blocks, which John has tried to get
>> people to understand, is that as long as an entity is paying the
>> renewal fees, while it might be apparent that the block is "on
>> autopilot" and is not in use/being sat on/etc. and that is incredibly
>> irritating, the existence of ongoing payments and ongoing claims that
>> the block is "in use" by the payor and the existence of the original
>> contract between the entity and the RIR, all of that establishes a
>> legal right to continue to have the registration, by that entity.
>>
>> If ARIN acts without consensus among the community, then it
>> jeopardizes the entire RIR system. We don't want the UN coming in and
>> taking it all over and the UN doesn't want to do that as long as the
>> RIR system appears to be functioning on consensus.
>>
>> The gray line is what constitutes legitimate operations of the RIR and
>> where is the line between that and operations that cannot happen
>> without consensus to modify the NRPM. I have argued in the past that
>> ARIN has enough authority by the NRPM to houseclean - John's statement
>> a few days ago contradicts that - which means as John said if we want
>> ARIN to take a broom to the legacy blocks, we have to give them more
>> authority to do so by modifying the NRPM.
>>
>> The actual truth is that if the community was united it could revoke
>> all legacy blocks tomorrow despite whatever legalities people out
>> there would argue. Ultimately it all comes down to what the major ISP
>> networks would accept, just because a RIR says a block is assigned to
>> someone else doesn't mean all the major ISPs are required to adhere to
>> that. In practice the major ISPs do because they prefer this over the
>> chaos that would result otherwise, but ultimately all a legacy block
>> is, is a checkoff in a database in ARIN. Nobody HAS to actually
>> follow it.
>>
>> We could vote in power to ARIN to revoke and they could do it. It
>> would be a hellofa mess and absolutely the wrong thing to do - but the
>> community absolutely does have the power to do it.
>>
>> Beyond that, absence of a proposal, it's all talk and no action. So I
>> guess if I want to see anything done I have to get cracking on a
>> proposal.
>>
>> Ted
>>
>> On 8/4/2022 7:42 PM, Paul E McNary wrote:
>>> 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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