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@arin.net> wrote:
On 22 Jul 2019, at 1:16 PM, William Herrin <bill@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