Re: 44/8

[Owen DeLong <owen () delong com>]

> On Jul 22, 2019, at 13:36 , John Curran <jcurran () arin net> wrote:
>
> On 22 Jul 2019, at 4:17 PM, Matthew Kaufman <matthew () matthew at <mailto:matthew () 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. 

The key word here is “appropriately”.

Until a few days ago, (and the reason the prior actions went largely unchallenged/unnoticed), ARDC (the organization, 
not the purpose) had not yet acted inappropriately in their administration of the sub assignments for the network on 
behalf of the community.

A few days ago, with ARIN complicit in the process, they took an inappropriate action not related to administering the 
sub assignments (or sub allocations in some cases) on behalf of the community and, instead, disposed of a significant 
fraction of the resources to enrich one particular organization without significant any vetting of the community in 
terms of their fitness for that purpose or the community’s willingness to part with said address space.

> > 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.   

Yes… It took the conspiracy of those entrusted with the responsible POC status on the block changing the name of the 
block to match their newly formed organization in order to carry this out. Likely from their perspective it was an 
effort to clean up the relationship between the AMPRNET and ARIN and until this action, with proper protections in 
place to prevent this action, I might have even consented to or supported that process. Unfortunately, that process 
took place largely in secret behind NDAs and other efforts to avoid community scrutiny until it was presented to the 
community as Faite Accompli. What you are hearing now is a lot of the community in question telling you that this was 
not the will of the community and that the organization in question had no such mandate from the community it claimed 
to be serving.

> > 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.

That would be ARDC, not ADCR, but here’s the problem… As far as most of us are concerned, it was inappropriate for ARIN 
to hand them control of the block in the first place. We were fine with them doing the record keeping and providing POC 
services, but we never expected them to be so bold as to simply steal community resources to enrich an organization we 
never vetted, no matter how well intended.

Owen

>  
>
> Thanks,
> /John
>
> John Curran
> President and CEO
> American Registry for Internet Numbers