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On 22 Jul 2019, at 4:17 PM, Matthew Kaufman <<a href="mailto:matthew@matthew.at" class="">matthew@matthew.at</a>> wrote:<br class="">
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<div dir="ltr" class="">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):
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<div class="">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 <a href="http://44.0.0.0/8" target="_blank" class="">44.0.0.0/8</a> 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
<a href="http://44.0.0.0/8" class="">44.0.0.0/8</a> 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.</div>
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<div class="">What *should* have happened at the time of the formation of ARIN and the other regional registries is that either 1) the <a href="http://44.0.0.0/8" target="_blank" class="">44.0.0.0/8</a> block have been delegated to a special-purpose RIR incorporated
to manage the amateur radio allocations within this block (which is what <a href="http://ampr.org/" target="_blank" class="">ampr.org</a> has been doing, but not as an IANA-recognized community-managed RIR); or 2) the <a href="http://44.0.0.0/8" target="_blank" class="">44.0.0.0/8</a> 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. </div>
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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. </div>
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<div>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. </div>
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<div class="">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.</div>
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<div class="">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.</div>
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<div class="">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. </div>
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<div class="">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. </div>
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<div class=""> 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.</div>
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<div>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. </div>
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<div>Thanks,</div>
<div>/John</div>
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<div>John Curran</div>
<div>President and CEO</div>
<div>American Registry for Internet Numbers</div>
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