Mike - The sample language I proposed was not intended to be interpreted as a proposed change to the ARIN RSA, but as a potential policy proposal. I do see how the current text could make that easy to misinterpret, and I’m happy to update the text to clarify as such.
Thanks, -C > On Sep 22, 2021, at 2:08 PM, Mike Burns <m...@iptrading.com> wrote: > > The devil is in the details, and ARIN staff relies on clear guidance from the > community, which I feel your proposal lacks. > What’s more I am not sure we can debate RSA changes on the PPML anyway. > Is that allowed? I thought the RSA was the domain of the Board. > > The entropy of the Internet tends to byzantine connections. > > Regards, > Mike > > > From: Chris Woodfield <ch...@semihuman.com> > Sent: Wednesday, September 22, 2021 4:56 PM > To: Mike Burns <m...@iptrading.com> > Cc: PPML <arin-ppml@arin.net> > Subject: Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement > > I disagree. There are a number of other parts of the NRPM that explicitly > gives ARIN staff the discretion to consider whether or not a specific request > or allocation is in line with policy, and this discretion is put in place > specifically to avoid the sort of whack-a-mole (yes, I’m happy to keep using > that phrase) technical workaround arms race that would need to be engaged in > otherwise. > > To your question as to whether a pencil-thin VPN would meet the test, that’s > exactly the question that this language gives ARIN staff the leeway to decide > or not. > > To put a bit more simply - intentions matter, and intentionally violating the > spirit of a policy should not be allowed by ARIN. > > -C > > >> On Sep 22, 2021, at 1:43 PM, Mike Burns <m...@iptrading.com >> <mailto:m...@iptrading.com>> wrote: >> >> Hi Chris, >> >> If you are serious about your proposal, then yes, it’s important to consider >> every potential issue, and not serious to refer to them as whack-a-mole. >> That is what the policy development process is all about. >> >> "No signatory to any ARIN RSA is permitted to issue addresses to customers >> who, in ARIN’s belief and discretion, are not contracting for a bona fide >> _network_ connectivity service _provided by the signatory_ that makes use of >> the allocated addresses" >> >> So I can make assignments of my address space to other networks, who can >> then advertise and use them with their own connectivity. That sounds a lot >> like leasing in practice, if not funding. Kind of hard to know who the >> customer actually is. Suppose I assign some of that pool to one of my >> customers via the cloud. So I am not connected to my customer at all, did I >> violate the RSA? >> >> Of course you know a pencil-thin VPN would meet the test, but there are many >> more moles to whack. >> >> Regards, >> Mike >> >> >> >> From: Chris Woodfield <ch...@semihuman.com <mailto:ch...@semihuman.com>> >> Sent: Wednesday, September 22, 2021 4:25 PM >> To: Mike Burns <m...@iptrading.com <mailto:m...@iptrading.com>>; PPML >> <arin-ppml@arin.net <mailto:arin-ppml@arin.net>> >> Subject: Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement >> >> >> >> >> >>> On Sep 22, 2021, at 1:12 PM, Mike Burns <m...@iptrading.com >>> <mailto:m...@iptrading.com>> wrote: >>> >>> (Back to this thread because I promised.) >>> >>> Thanks for calling out an obvious bug, I should have noticed it myself. >>> Updated clause, changes bracketed by underlines: >>> >>> "No signatory to any ARIN RSA is permitted to issue addresses to customers >>> who, in ARIN’s belief and discretion, are not contracting for a bona fide >>> _network_ connectivity service _provided by the signatory_ that makes use >>> of the allocated addresses" >>> >>> -C >>> >>> Say I am the registrant and I assign the block to my cloud provider to >>> advertise under their ASN and connectivity. >> >> No, because the cloud provider is not your customer. >> >>> Did I violate the RSA? >>> What if the cloud provider offers payment if I share my pool with other >>> users of that cloud network? >> >> That would be an RSA violation, as at that point, the cloud provider *does* >> become your customer, that is purchasing the use of your address space, but >> not a connectivity service to them. >> >> We can play the whack-a-mole game as long as you like, but the main point of >> the chosen language is that it gives ARIN staff the discretion to see >> through attempts at working around any sort of technical definition of an >> address lease, and call out the practice for what it is, no matter how the >> organization attempts to claim otherwise via an increasingly-byzantine >> technical structure. >> >> -C >> >> >> >>> >>> Regards, >>> Mike >>> >>> >>> From: ARIN-PPML <arin-ppml-boun...@arin.net >>> <mailto:arin-ppml-boun...@arin.net>> On Behalf Of Mike Burns >>> Sent: Wednesday, September 22, 2021 11:50 AM >>> To: 'Chris Woodfield' <ch...@semihuman.com <mailto:ch...@semihuman.com>>; >>> 'PPML' <arin-ppml@arin.net <mailto:arin-ppml@arin.net>> >>> Subject: Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit >>> Requirement >>> >>> Hi Chris, >>> >>> I am still unclear. So the “risk” you refer to is the inability to purchase >>> new blocks using leases as justification? >>> I’m not entirely sure how that constitutes a risk, unless you mean they >>> will run out of addresses they need for themselves. Is that their risk? >>> >>> It seems like you are objecting to a proposal to allow using leased >>> addresses as justification by simply stating that you don’t like leasing. >>> >>> Why can’t you stand behind this distribution method, can you be clear on >>> your objection to leasing? >>> Because certainly this proposal facilitates leasing. >>> >>> I guess we are coming to the crux of things now, I’ve asked a few people >>> who have opposed this policy why, and for some it comes down to >>> disapproving of leasing. Now I’ve asked why. >>> >>> A good reason, to me, is that leasing often serves the needs of miscreants. >>> But leasing is allowed, so miscreants are currently being served. My >>> experience tells me that miscreants have the advantage over most incumbent >>> lessors, who are generally not in the business of leasing addresses. >>> >>> ARIN policy prevents newcomers into the leasing business, and I think >>> professional lessors will provide some balance against miscreants if they >>> were allowed to enter that market. >>> >>> Regards, >>> Mike >>> >>> >>> >>> >>> >>> >>> From: Chris Woodfield <ch...@semihuman.com <mailto:ch...@semihuman.com>> >>> Sent: Wednesday, September 22, 2021 11:33 AM >>> To: PPML <arin-ppml@arin.net <mailto:arin-ppml@arin.net>> >>> Cc: Owen DeLong <o...@delong.com <mailto:o...@delong.com>>; Mike Burns >>> <m...@iptrading.com <mailto:m...@iptrading.com>> >>> Subject: Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit >>> Requirement >>> >>> I’m speaking to the risk that an organization that engages in leasing >>> address blocks without providing related connectivity services. Given that >>> these blocks cannot currently be used as justification for additional >>> space, an organization that does so would not qualify for additional space >>> should they require it, unless they are falsifying the nature of the >>> allocations in their justification documentation (which, of course, is a >>> policy violation that could lead to that organizations’s allocations being >>> reclaimed if discovered). >>> >>> This policy proposal, per the problem statement, is explicitly aimed at >>> removing that risk, and as such, putting ARIN’s stamp of approval on this >>> type of lease practice, and in fact, allows organizations to require >>> additional space which it could then lease out, without the need to provide >>> the network services associated with the blocks being leased. Which is a >>> type of IP block monetization that I simply cannot stand behind. >>> >>> As such, I remain opposed to this proposal. >>> >>> -C >>> >>> >>>> On Sep 22, 2021, at 7:00 AM, Mike Burns <m...@iptrading.com >>>> <mailto:m...@iptrading.com>> wrote: >>>> >>>> Hi Chris, >>>> >>>> Can you be more specific on which inherent risk this policy would remove? >>>> Somebody +1’d this, but I don’t understand what you mean. >>>> I don’t even know which party’s risk is being commented on. >>>> >>>> Regards, >>>> Mike >>>> >>>> >>>> From: ARIN-PPML <arin-ppml-boun...@arin.net >>>> <mailto:arin-ppml-boun...@arin.net>> On Behalf Of Chris Woodfield >>>> Sent: Tuesday, September 21, 2021 9:21 PM >>>> To: Owen DeLong <o...@delong.com <mailto:o...@delong.com>> >>>> Cc: PPML <arin-ppml@arin.net <mailto:arin-ppml@arin.net>> >>>> Subject: Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit >>>> Requirement >>>> >>>> >>>>> On Sep 21, 2021, at 10:22 AM, Owen DeLong <o...@delong.com >>>>> <mailto:o...@delong.com>> wrote: >>>>> >>>>> This policy doesn’t affect that… Leasing of address space you already >>>>> have is permitted under current policy and cannot be grounds for >>>>> revocation of address space. >>>>> >>>>> The change in this policy proposal is not to permit or deny leasing, but >>>>> to permit leased addresses to be considered utilized for purposes of >>>>> determining eligibility for additional address acquisition. >>>>> >>>> >>>> You are correct that the proposal may not permit or prohibit leasing, but >>>> it does (intentionally, per the problem statement) remove one of the >>>> inherent risks of the practice, and as such, in my view, is effectively an >>>> endorsement. >>>> >>>> As such, my opposition stands. >>>> >>>> -C >>>> >>>> >>>> >>>> >>>> >>>>> Owen >>>>> >>>>> >>>>> >>>>> >>>>> >>>>> >>>>>> On Sep 21, 2021, at 08:22 , Chris Woodfield <ch...@semihuman.com >>>>>> <mailto:ch...@semihuman.com>> wrote: >>>>>> >>>>>> Writing in opposition. I do not support the practice of leasing IP >>>>>> address resources. Organizations who have received larger amounts of IP >>>>>> address space than what they are efficiently utilizing are free to >>>>>> relieve themselves of their excess space via the transfer market. >>>>>> >>>>>> Thanks, >>>>>> >>>>>> -Chris >>>>>> >>>>>> >>>>>> >>>>>> >>>>>> >>>>>>> On Sep 21, 2021, at 8:06 AM, ARIN <i...@arin.net >>>>>>> <mailto:i...@arin.net>> wrote: >>>>>>> >>>>>>> On 16 September 2021, the ARIN Advisory Council (AC) accepted >>>>>>> "ARIN-prop-302: Remove Circuit Requirement " as a Draft Policy. >>>>>>> >>>>>>> Draft Policy ARIN-2021-6 is below and can be found at: >>>>>>> >>>>>>> https://www.arin.net/participate/policy/drafts/2021_6/ >>>>>>> <https://www.arin.net/participate/policy/drafts/2021_6/> >>>>>>> >>>>>>> You are encouraged to discuss all Draft Policies on PPML. The AC will >>>>>>> evaluate the discussion in order to assess the conformance of this >>>>>>> draft policy with ARIN's Principles of Internet number resource policy >>>>>>> as stated in the Policy Development Process (PDP). Specifically, these >>>>>>> principles are: >>>>>>> >>>>>>> * Enabling Fair and Impartial Number Resource Administration >>>>>>> * Technically Sound >>>>>>> * Supported by the Community >>>>>>> >>>>>>> The PDP can be found at: >>>>>>> >>>>>>> https://www.arin.net/participate/policy/pdp/ >>>>>>> <https://www.arin.net/participate/policy/pdp/> >>>>>>> >>>>>>> Draft Policies and Proposals under discussion can be found at: >>>>>>> https://www.arin.net/participate/policy/drafts/ >>>>>>> <https://www.arin.net/participate/policy/drafts/> >>>>>>> >>>>>>> Regards, >>>>>>> >>>>>>> Sean Hopkins >>>>>>> Senior Policy Analyst >>>>>>> American Registry for Internet Numbers (ARIN) >>>>>>> >>>>>>> >>>>>>> Draft Policy ARIN-2021-6: Remove Circuit Requirement >>>>>>> >>>>>>> Problem Statement: >>>>>>> >>>>>>> Current ARIN policy prevents the use of leased-out addresses as >>>>>>> evidence of utilization. >>>>>>> >>>>>>> Policy statement: >>>>>>> >>>>>>> Replace >>>>>>> >>>>>>> “2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is >>>>>>> an IR that primarily assigns address space to the users of the network >>>>>>> services that it provides. LIRs are generally Internet Service >>>>>>> Providers (ISPs), whose customers are primarily end users and possibly >>>>>>> other ISPs.” >>>>>>> >>>>>>> with >>>>>>> >>>>>>> “2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is >>>>>>> an IR that primarily assigns address space to users of the network. >>>>>>> LIRs are generally Internet Service Providers (ISPs), whose customers >>>>>>> are primarily end users and possibly other ISPs.” >>>>>>> >>>>>>> Timetable for implementation: Immediate >>>>>>> >>>>>>> _______________________________________________ >>>>>>> ARIN-PPML >>>>>>> You are receiving this message because you are subscribed to >>>>>>> the ARIN Public Policy Mailing List (ARIN-PPML@arin.net >>>>>>> <mailto:ARIN-PPML@arin.net>). >>>>>>> Unsubscribe or manage your mailing list subscription at: >>>>>>> https://lists.arin.net/mailman/listinfo/arin-ppml >>>>>>> <https://lists.arin.net/mailman/listinfo/arin-ppml> >>>>>>> Please contact i...@arin.net <mailto:i...@arin.net> if you experience >>>>>>> any issues. >>>>>> >>>>>> >>>>>> _______________________________________________ >>>>>> ARIN-PPML >>>>>> You are receiving this message because you are subscribed to >>>>>> the ARIN Public Policy Mailing List (ARIN-PPML@arin.net >>>>>> <mailto:ARIN-PPML@arin.net>). >>>>>> Unsubscribe or manage your mailing list subscription at: >>>>>> https://lists.arin.net/mailman/listinfo/arin-ppml >>>>>> <https://lists.arin.net/mailman/listinfo/arin-ppml> >>>>>> Please contact i...@arin.net <mailto:i...@arin.net> if you experience >>>>>> any issues.
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