I recently submitted yet another policy proposal to ARIN, building on the previous work of ARIN-prop-133. This new proposal is an alternative to the “opt-in” model, rather providing an “opt-out” approach.

It shouldn’t need to be said, that if both proposals are rejected then ARIN is effectively saying that legacy address holders have “no option” but to submit to regulation. Maybe this is what the ARIN policy community wants, in which case even the failure of these proposals will have been successful in clarifying policy.

ARIN-prop-136: Services Opt-out Allowed for Unaffiliated Address Blocks

Proposal Originator:  Benson Schliesser

Proposal Version:  1

Date:  23 Feb 2011

Proposal type:  New

Policy term:  Permanent

Policy statement:

Add the following to the NRPM:

13.  Unaffiliated Address Blocks

13.x. Opt-out Allowed

ARIN provides IP address registry services to all IP address holders in
the ARIN region, for all IP address resources that are not registered by
another RIR, regardless of whether any given address holder has entered
into a services agreement.  However, ARIN will cease providing any
registry services for specific IP address resources in the event that
the legitimate address holder of an unaffiliated address block, that is
an address block that is not covered by an ongoing services agreement,
chooses to opt-out of receiving any or all registry services from ARIN.

13.x.1. Requirements for Whois Opt-out

In order for an opt-out request for Whois directory services to be
valid, the legitimate address holder must agree to provide a replacement
directory service reflecting operationally accurate allocation and
assignment information for the specified IP number resources.  ARIN will
create generic placeholder entries in the ARIN Whois directory for all
IP number resources that are removed due to opt-out, and each
placeholder entry will include a reference and/or RWhois referral to the
replacement directory service.

Rationale:

This proposal does not seek to replace ARIN-prop-133 but is offered as
an exclusive alternative for consideration by the ARIN community, in
order to address concerns that it would unfairly harm legacy address
holders and/or cause unnecessary damage to the Whois database.

Policy Background:

This policy attempts to clarify the relationship that ARIN has with
legacy address holders.

Specifically, this policy recognizes that absent an agreement such as
the RSA or LRSA there is no formal relationship with legacy address
holders.  At present, however, ARIN continues to provide services to
these organizations.  This is done without compensation and potentially
in opposition to the legacy address holders’ wishes.  As a result of
this behavior ARIN has created an illusion of implied authority that
exposes ARIN to unacceptable levels of liability, is hindering the
development of an open address market (driving it “underground”), and is
putting the operational stability of the Internet at risk.  As new
services such as RPKI are contemplated this situation becomes even more
critical.

This policy assumes the tacit consent of all address holders in the ARIN
region, to receive ARIN registry services and to be governed by ARIN
policy, but allows for legitimate address holders of unaffiliated
address blocks to explicitly opt-out of any and/or all services.  This
approach would allow ARIN to continue providing volunteer services to
any member of the legacy community as long as this service was not
contrary to their wishes.  Further, it would allow legacy address
holders to opt-out of some services such as Whois while continuing to
receive other services such as in-addr DNS reverse mapping.

In the event that a legacy address holder does opt-out of Whois
directory services under this policy, ARIN would require the address
holder to provide a replacement directory service and would continue to
provide a Whois pointer (such as a RWhois referral) to that service.  As
a result, the integrity of the distributed Whois database would remain
intact and be improved.

Timetable for implementation:  Immediately

A couple days ago I submitted another policy proposal to ARIN, entitled No Volunteer Services on Behalf of Unaffiliated Address Blocks. The text of the proposal submission is below.

This is a complicated topic, and I expect the discussion to evolve the proposal text significantly. More importantly, however, I hope the proposal text evolves the discussion.

ARIN-prop-133: No Volunteer Services on Behalf of Unaffiliated Address Blocks

Proposal Originator: Benson Schliesser

Proposal Version: 1

Date: 13 February 2011

Proposal type: New

Policy term: Permanent

Policy statement:

Add the following to the NRPM:

13. Unaffiliated Address Blocks

13.1. No Volunteer Services

Except in the specific circumstances described by this policy, ARIN will
not provide any services for any organization and/or address block. This
includes without limitation all directory services, reverse mapping
services, and future services that may be provided to the community.

13.1.1. Requested Services

In the event that an organization explicitly requests registry services
from ARIN for one or more specified address blocks, ARIN may provide the
requested services, subsequent to execution of a service contract, for
those address blocks. This includes without limitation all directory
services, reverse mapping services, and future services that may be
provided to the community.

All address blocks that are assigned or allocated by ARIN under a valid
RSA, as well as specific address blocks that are included under a Legacy
RSA with the legitimate validated address holder, are deemed to have
services requested for them.

An organization requesting registry services for one or more specified
address blocks, that also holds additional address blocks not specified
in their request, is not obligated to receive registry services for
those additional address blocks and those blocks are not deemed to have
services requested for them.

13.1.2. Directory Placeholders

For any address blocks, for which there are not fully executed ARIN
service contracts, ARIN will create generic placeholder entries in the
ARIN Whois directory. These placeholder entries will not specify
organizational details, but will indicate that the entry represents a
non-member resource.

When applicable, each non-member resource placeholder will include a
reference and/or RWhois referral to the authoritative directory service
for that block, or the directory service operated by the IANA, or by
another organization in the event that IANA has delegated their
directory service responsibility to that organization. This does not
apply to placeholders that represent an unassigned and unallocated
address block delegated to ARIN by the IANA.

13.2. Recognition of Legitimate Address Holders

ARIN will use the following criteria in order to determine whether an
organization is the legitimate address holder for a given IP address block.

13.2.1. Original Allocation Record

The original allocation records, such as those documented in RFC 1166
issued in July of 1990 or the InterNIC database received by ARIN from
Network Solutions in December of 1997, will be used as dispositive
proof, absent any contrary documentation such as those specified in
section 13.2.4 below, in determining whether an organization is the
legitimate address holder.

13.2.2 IANA Records of Legitimate Address Holders

In the event that the IANA has historical records, and/or current
records, showing the assignment or allocation of a given IP address
block to a specific organization, those records will be used as proof,
absent any contrary documentation, in determining whether an
organization is the legitimate address holder.

Further, in the event that this evidence conflicts with any evidence
from the original allocation records, or any contrary documentation such
as those specified in section 13.2.4 below, the evidence from the
original allocation record will take precedence.

13.2.3. Records Maintained on Behalf of the IANA

In the event that the IANA has delegated responsibility for the
management of an address block to another organization, including ARIN
or any other RIR, and that organization has historical and/or current
records showing the assignment or allocation of a given IP address block
to a specific organization, those records will be used as evidence in
determining whether an organization is the legitimate address holder.

Further, in the event that this evidence conflicts with any evidence
from the original allocation records, or any contrary documentation such
as those specified in section 13.2.4 below, the evidence from the
original allocation record will take precedence.

13.2.4. Formal Records Clarifying the Chain of Custody

In the event that formal records, such as public records or other formal
documents which can be authenticated or verified to include legal,
financial, and other organizational documentation, are provided to ARIN
by an organization seeking recognition of their status as the legitimate
address holder, then ARIN will consider the impact of these records as
potentially updating any evidence that may exist. If these records
clearly document the assignment or allocation of a given IP address
block to a specific organization by direct assignment, and/or
organizational transitions such as mergers, acquisitions, business unit
restructuring, asset transfers, name changes, and so forth, absent
definitive documentation to the contrary, then these records will
determine whether an organization is the legitimate address holder.

13.3. Permitted Updates to Directory Services for Unaffiliated Address
Blocks

Any organization that legitimately holds an address block, as defined by
section 13.2 of this policy, may request the removal or modification of
existing directory placeholders representing that address block.

Valid requests for modification of placeholder entries are limited to
references and/or RWhois referrals to authoritative directory services,
such as directory services operated by or on behalf of the IANA, another
address registry, or the address holder. In the event that such a
request is received, ARIN may choose to either remove the placeholder
entry or update it per the request.

Rationale:

Policy Background:

This policy attempts to clarify the relationship that ARIN has with
legacy address holders.

Specifically, this policy recognizes that absent an agreement such as
the RSA or LRSA there is no formal relationship with legacy address
holders. At present, however, ARIN continues to provide services to
these organizations. This is done without compensation and potentially
in opposition to the legacy address holders’ wishes. As a result of
this behavior ARIN has created an illusion of implied authority that
exposes ARIN to unacceptable levels of liability, is hindering the
development of an open address market (driving it “underground”), and is
putting the operational stability of the Internet at risk. As new
services such as RPKI are contemplated this situation becomes even more
critical.

This policy would require positive affirmation from any legacy address
holder that wishes to receive registry services, moving to an “opt-in”
approach. In the event that a legacy address holder does not opt-in to
receive registry services, ARIN is limited to providing no more than a
pointer (such as a RWhois referral) to an authoritative directory
service for that holder’s legacy address blocks. Pointers to other
providers of directory services for addresses managed by those
other providers continue to be permitted.

Policy Structure:

This policy introduces a new section to the NRPM, numbered section 13.
Within this new section, there are three sub-sections.

Sub-section 13.1 introduces policy that limits ARIN to providing
services on an opt-in basis. It does make clear in 13.1.1 that services
provided as part of a RSA or LRSA are automatically considered opted-in.
With 13.1.2 it allows ARIN to create placeholders in the Whois
database for blocks managed by other RIRs as well as for blocks managed
(but unassigned/unallocated) by ARIN.

Sub-section 13.2 introduces policy that specifies how ARIN will go about
determining who a “legitimate” address holder is. It is similar to
current procedure with 13.2.2 and 13.2.3, which specify the use of IANA
and RIR records. It expands on the current procedures with 13.2.4,
allowing organizations to provide legal documentation of organizational
changes and/or the transfer of custody of a legacy address block.

Sub-section 13.3 introduces policy enabling legitimate address holders
to request a very limited update to any Whois placeholders that might
exist for their legacy address block, so that the Whois will refer
queries to the authoritative directory service. It is expected that
ARIN will charge a fee for this update, but not require an ongoing
services agreement. ARIN is given the option of deleting placeholders
instead.

Timetable for implementation: Immediately

Yesterday evening I submitted a policy proposal to ARIN, with the effect of enabling address holders to “lease” IP addresses. Traditionally, an ISP might have provided addresses (for a fee or for free) as part of a network connectivity service. There is currently no policy that mandates that relationship, however, and this policy proposal is an attempt to clarify that no specific relationship is required.

ARIN-prop-132: ISP Sub-assignments Do Not Require Specific Customer Relationships

Proposal Originator: Benson Schliesser

Proposal Version: 1

Date: 11 February 2011

Proposal type: modify

Policy term: permanent

Policy statement:

Section 4.2.1.1 of the NRPM shall be modified to read:

“ARIN allocates blocks of IP addresses to ISPs for the purpose of
reassigning that space to their customers. ARIN does not limit
reassignment by ISPs to their customers based on any criteria except
those that are explicitly described in the NRPM. An ISP is solely
responsible for determining whether an organization is a customer for
the purposes of reassignment under this policy.”

Rationale:

This policy proposal is intended to permit an ISP to enter into
reassignment relationships with anybody they deem to be a customer.
Under this proposal, ARIN will not object to reassignment relationships
because of their business nature. This specifically permits the
reassignment of IPv4 addresses in “lease” relationships between an ISP
and its customers, amongst others.

Timetable for implementation: immediately