44/8

Mon Jul 22 20:17:47 UTC 2019

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 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
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 block have been
delegated to a special-purpose RIR incorporated to manage the amateur radio
allocations within this block (which is what ampr.org has been doing, but
not as an IANA-recognized community-managed RIR); or 2) the 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.

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.

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. And nobody from ARIN asked us if we thought
ARDC was a suitable proxy for our interests in the special use of the space
either when the registration was transferred to the corporation or when the
registration stopped being used solely for its original purpose. 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.

Matthew Kaufman

On Mon, Jul 22, 2019 at 12:26 PM John Curran <jcurran at arin.net> wrote:

> On 22 Jul 2019, at 1:16 PM, William Herrin <bill at herrin.us> wrote:
> >
> > Respectfully John, this wasn't a DBA or an individual figuring the org
> name field on the old email template couldn't be blank. A class-A was
> allocated to a _purpose_.
>
> Bill -
>
> The block in question is a /8 research assignment made with a particular
> network name and a particular responsible technical contact, just as so
> many other research networks during that period; indeed, if that is what
> you meant by “purpose”, then you are correct.   Like so many of those early
> research networks, the evolution of the block over time was under control
> of the contact listed in the registry, and resulted in some being returned,
> some ending up with commercial firms, some with not-for-profit entities,
> etc.
>
> In the case of AMRPNET, in 2011 ARIN did approve update of the
> registration to a public benefit not-for-profit at the request of the
> registered contact.
>
> > You've not only allowed but encouraged that valuable resource to be
> reassigned to an organization, this ARDC, and then treated the organization
> as a proxy for the purpose. No one asked you to do that.
>
> Again, ARIN was specifically requested to do exactly that by the
> authoritative contact, and it was correct to proceed given that the IP
> block was a general purpose IP address block absent any other policy
> guidance.
>
> > Nothing in the publicly vetted policies demanded that you attach
> organizations to the purpose-based allocations
>
> You’ve suggested that this network was some special “purpose-based”
> allocation, but failed to point to any actual policy guidance that
> distinguishes it in that manner.    Note that we do have many such
> documents that identify a variety of purpose-based allocations – for
> example, RFC 5737 ("IPv4 Address Blocks Reserved for Documentation”),  RFC
> 6598 for 'Shared Address Space' for CGN, etc.  If you do have a IETF or
> IANA policy document applicable to AMPRNET that somehow has been
> overlooked, please provide it to ARIN as part of an Internet number
> resource fraud report, and we will promptly review and investigate.
>
> In the meantime, if you are curious about the actual IPv4 special-purpose
> assignments, you can find the complete list here:
> https://www.iana.org/assignments/iana-ipv4-special-registry/iana-ipv4-special-registry.xhtml
> – there’s quite a few, but AMPRNET is not one of them.
>
> Thanks,
> /John
>
> John Curran
> President and CEO
> American Registry for Internet Numbers
>
>
>
>
>
>
>
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