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

Ted Mittelstaedt tedm at ipinc.net
Sat Aug 6 18:24:29 EDT 2022 

Once more, nobody cares about those because they are _in use_.

Interesting that there's a handful of legacy space in other RIRs.  I 
hadn't thought about transfers.  However I don't believe transfers
can happen unless they sign an LSRA so they are "in the system" at that
point.

Ted

On 8/6/2022 2:19 PM, Mike Burns wrote:
> Just a point of clarification.
> ARIN is not the only RIR with legacy blocks.
> Check ARIN ERX Transfers.
> Every RIR has them, and has similar policies regarding them.
> There are some significant differences related to transfers of legacy space.
> 
> Regards,
> Mike
> 
> 
> 
> 
> ------- Original Message -------
> *From :* Ted Mittelstaedt[mailto:tedm at ipinc.net]
> *Sent :* 8/6/2022 4:10:28 PM
> *To :* lee at dilkie.com; pmcnary at cameron.net
> *Cc :* arin-ppml at arin.net
> *Subject :* RE: Re: [arin-ppml] ARIN actions regarding address blocks 
> with no valid POCs (was: Re: Deceased Companies?)
> 
> 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/>
>  >>>> < 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/>
>  >>>> < 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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