On 22 Jul 2019, at 4:17 PM, Matthew Kaufman
<matt...@matthew.at<mailto:matt...@matthew.at>> wrote:
The change in character/purpose of the network has operational impacts to me,
and as such should have been done as an IANA action (as the original purpose
was arguably also set by IANA action, when IANA was Jon Postel, and simply not
documented very well):
I am the network administrator for a 501(c)(3) amateur radio club that operates
a digital microwave network licensed via FCC Part 101 (commercial microwave),
FCC Part 15 ("unlicensed" ISM) and FCC Part 97 (amateur radio). The Part 97
links are, by law, restricted to amateur radio uses. One way to ensure this is
to filter based on the fact that 44.0.0.0/8<http://44.0.0.0/8> is for
international amateur radio use only. That has changed as a result of ARIN's
consent to a "transfer" to an entity that will not be using these for the
originally stated purpose. We have a /23 allocated within
44.0.0.0/8<http://44.0.0.0/8> and it is likely that as we expand we will need
additional address space, so the transfer of some of the unallocated space is
of concern for that reason as well.
What *should* have happened at the time of the formation of ARIN and the other
regional registries is that either 1) the 44.0.0.0/8<http://44.0.0.0/8> block
have been delegated to a special-purpose RIR incorporated to manage the amateur
radio allocations within this block (which is what ampr.org<http://ampr.org/>
has been doing, but not as an IANA-recognized community-managed RIR); or 2) the
44.0.0.0/8<http://44.0.0.0/8> block have been delegated to another RIR (e.g.,
ARIN) that could have special policies applicable only to that block and
managed by the community.
There is no such creature as a “special purpose” RIR; Regional Internet
Registries serve the general community in a particular geographic regions as
described by ICANN ICP-2.
I would note that ARIN’s original “region” was actually fairly broad
(everything not in the RIPE or APNIC regions, just as InterNIC had served), and
this included numerous “unusual" allocations to various international projects
such as research stations, global airline networks, consortia, and other
purposes both of formal legal structure and otherwise. In all cases, the
entities successfully administer subassignments based on their own unique
policies; it is not necessary for the IANA or an RIR to be involved in such
special purpose networks, so long as there is a party appropriately
administering the sub assignments for the network on behalf of the particular
community.
I would guess that in either case, the odds that the community would have
decided to peel off 1/4 of the space and sell it to a commercial entity would
have been low, and that the odds that IANA would have agreed to go along with
such a thing at least as low.
Instead we're here, because ARIN treated "Amateur Radio Digital Communications"
not as a purpose (that happened to not be documented well via RFC or other
process) but as an organization name that anyone could adopt, given sufficient
documentation. Despite the fact that the block was already being used in a way
that you'd expect an RIR to be behaving, not the way the organization has
behaved.
Matthew - It is completely incorrect that all it took was "an organization name
that anyone could adopt, given sufficient documentation” –≈ the organization
name is not sufficient; you need to have the authorized contact for IP address
block make such a request – as administration of the block was entrusted to the
contact, and the party requesting needs to be the original registrant or their
designated successor in a clear chain of authority.
Again, I'm sure that this was all well-intentioned... but nobody from ARDC
asked any of the hams like me who've been sending TCP/IP over ham radio since
it was possible, and have active allocations within the 44 net what we thought
about this idea.
...
That's why a real RIR for this space would have had a policy development
process where *the community* could weigh in on ideas like "sell of 1/4 of it
so we can have a big endowment". Which, heck, we might have all agreed to... if
there was some transparency.
Those are excellent questions for ADCR regarding its governance and
accountability plans, but again, none of that requires any special “RIR” magic
to accomplish; it simply takes a not-for-profit organization that serves its
community – such entities are quite common but they require an active and
engaged community and appropriate governance structures.
Thanks,
/John
John Curran
President and CEO
American Registry for Internet Numbers
