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" <t...@ipinc.net>
To: "John Curran" <jcur...@arin.net>
Cc: "arin-ppml" <arin-ppml@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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