Re: Past policies versus present and future uses

2021-01-26 Thread Rich Kulawiec
On Mon, Jan 25, 2021 at 11:26:51AM -0500, Rob McEwen wrote:
> Is DDoS-Guard without blame? Probably not, but them hosting some occasional
> criminals is NOT UNLIKE EVERY OTHER GLOBAL NETWORK!

You might wish to scroll back up to the message I sent here on January 21
with the Subject "DDOS-Guard"  and note the list of domains that I provided.

That's not a network with "occasional" issues, that's a network with
pervasive issues.

> By these SAME standards, many other large and famous
> networks should lose most or much of their IPs too!

Yes, that's exactly what should happen.  "Large and famous" operations,
by their very nature, have plenty of money to spend on large, trained,
competent, empowered, 24x7 abuse staff as well as on customer screening
-- and should do that.  Those that don't should not have their problematic
allocations confiscated: they should have *all* their allocations confiscated.

Why?  Well, first because there are no acceptable excuses for running
an operation like that.  NONE.  And second, because when those operations
refuse to pay the costs of keeping abusers out, you know who *does* pay
for that?

We do.

---rsk


Re: Past policies versus present and future uses

2021-01-25 Thread Rob McEwen

On 1/25/2021 11:34 AM, Rubens Kuhl wrote:

They are not losing IPs because of hosting questionable content.


Correct - but from reading the Brian Krebs article on this, that was the 
justification that Ron Guilmette used for going after Parler and DDoS-Guard.


--
Rob McEwen
https://www.invaluement.com
+1 (478) 475-9032




Re: Past policies versus present and future uses

2021-01-25 Thread Rubens Kuhl
On Mon, Jan 25, 2021 at 1:28 PM Rob McEwen  wrote:

>
> A take on the 1979 movie "When A Stranger Calls" - "have you checked the
> children?" becomes "have you checked the IP registration?"
>
> [image: Have you checked the IP registration?]
>
>
> The vast majority of the time, Ron Guilmette does "the Lord's work" - but
> THIS time - it looks to me like he put his political biases ahead of legit
> anti-abuse, and it's no surprise that we now have a trail of destruction
> left behind, along with much "innocent bystander" collateral damage.
>
> Is DDoS-Guard without blame? Probably not, but them hosting some
> occasional criminals is NOT UNLIKE EVERY OTHER GLOBAL NETWORK! So like
> other large and diversity global networks, anti abuse should focus on
> removing their worst criminals/spammers. By these SAME standards, many
> other large and famous networks should lose most or much of their IPs too!
>
> So here we are, with many OTHER networks now legitimately freaked out
> about losing their IPs, and with massive potential collateral damage that
> might hurt many "innocent bystanders" each time that is done!
>
>
They are not losing IPs because of hosting questionable content. It's very
reassuring to see RIR policies being enforced; there is a sentiment of lack
of accountability in IP allocations and that changing is positive for all
the ecosystem.


Rubens


Re: Past policies versus present and future uses

2021-01-25 Thread Rob McEwen
/(sent again since the last one had the inline graphic stripped out - so 
this one links to the graphic on a website)/


A take on the 1979 movie "When A Stranger Calls" - "have you checked the 
children?" becomes "have you checked the IP registration?"


Have you checked the IP registration?

https://www.invaluement.com/have-you-checked-the-ip-registration.jpg

The vast majority of the time, Ron Guilmette does "the Lord's work" - 
but THIS time - it looks to me like he put his political biases ahead of 
legit anti-abuse, and it's no surprise that we now have a trail of 
destruction left behind, along with much "innocent bystander" collateral 
damage.


Is DDoS-Guard without blame? Probably not, but them hosting some 
occasional criminals is NOT UNLIKE EVERY OTHER GLOBAL NETWORK! So like 
other large and diversity global networks, anti abuse should focus on 
removing their worst criminals/spammers. By these SAME standards, many 
other large and famous networks should lose most or much of their IPs too!


So here we are, with many OTHER networks now legitimately freaked out 
about losing their IPs, and with massive potential collateral damage 
that might hurt many "innocent bystanders" each time that is done!


-- Rob McEwen, invaluement



Re: Past policies versus present and future uses

2021-01-25 Thread Rob McEwen


A take on the 1979 movie "When A Stranger Calls" - "have you checked the 
children?" becomes "have you checked the IP registration?"


Have you checked the IP registration?


The vast majority of the time, Ron Guilmette does "the Lord's work" - 
but THIS time - it looks to me like he put his political biases ahead of 
legit anti-abuse, and it's no surprise that we now have a trail of 
destruction left behind, along with much "innocent bystander" collateral 
damage.


Is DDoS-Guard without blame? Probably not, but them hosting some 
occasional criminals is NOT UNLIKE EVERY OTHER GLOBAL NETWORK! So like 
other large and diversity global networks, anti abuse should focus on 
removing their worst criminals/spammers. By these SAME standards, many 
other large and famous networks should lose most or much of their IPs too!


So here we are, with many OTHER networks now legitimately freaked out 
about losing their IPs, and with massive potential collateral damage 
that might hurt many "innocent bystanders" each time that is done!


-- Rob McEwen, invaluement



Re: Past policies versus present and future uses

2021-01-24 Thread JORDI PALET MARTINEZ via NANOG
Hi Matthew,

 

I’m not sure I’ve succeded to explain it in previous emails.

The requirement for the LACNIC policies about majority of usage *in the region* 
of the resources provided has been there for many years. I’m almost sure than 
since day 1, but will need to dig into older versions of the policy manual to 
check that.

The *text* was only using the work “mayoría”, but the interpretation when 
ensuring policy compliance, was following that definition of “mayoria”, which 
is more than 50%. My policy proposal, was “cleaning” and “clarifiying” text 
here and there. For example, there were some text that clearly apply to IPv4 
and IPv6, and was only in the IPv4 section, etc. The policy proposal also did a 
lot of major changes for the recovery of uncompliant addressing space by 
ensuring that LACNIC setup periodic and automatic policy compliance checks.

So: the “>50%” was not a “change”, was just making explicit the actual 
practice, and during the discussion of the proposal, we made sure in the 
mailing list that everybody agree with that clarification of the *existing* 
interpretation. Nobody, absolutely nobody, objected or said “I don’t read it 
that way”. In fact, I asked if the people prefers to use some “other %”, or 
completely delete it or whatever.

I don’t have the exact details of the case that Ron discovered in Belize, 
because, of course, most of the details are under NDA between the resourse 
holder and LACNIC, private documents, etc., etc. So I’m not sure if “initially” 
the resource holder was really having the “majority” of the resources operated 
in Belize or some other place in the region and then they “forgot” that they 
need to follow the policy (as said, the policy has not changed in that sense). 
My guess is that they provided false information to LACNIC “yes we have the 
majority of the operation in the region”, and the RIR trusted the provided 
documents, but is only my guess.

I fully see your point, however *every ISP/LIR needs to follow the policies in 
every RIR where they have resources*. Policy changes may require changes in 
their operation, and if they don’t agree, *this is the reason* they MUST 
participate in policy discussions, to be able to defend their position.

This is *nothing new*! Is part of the job of the ISPs/LIRs, to ensure that they 
follow the policy discussions, the same way as citizens follow law development 
because changes in law (new taxes, etc.), can change their compliance with law. 
Is not about retroactivity, is about every one of us developing the “laws” and 
justify why something can’t be changed.

The solution to those that don’t want to follow (even if is part of their 
“job”) the policy development, is to have warnings when there is a policy 
change that affects them. In fact I’ve included that in a policy proposal in 
AFRINIC 
(https://www.afrinic.net/policy/proposals/2020-gen-001-d1?lang=en-GB#proposal), 
by means of a dash-board. This could be done also by other RIRs as part of 
their “operational” terms in the customers accounts (such in “mylacnic” in the 
case of LACNIC), etc., and in fact it was the main intent of my policy proposal.

As said, remember that this has been not changed, just added a clarification 
based on the existing understanding of the previuos text. LACNIC will not have 
provided to this resource-holder in 2013 the resources if they didn’t had 
indicated that the majority (over 50%) of those resrouces aren’t being operated 
in the region.

I found and older archived version of the policy manual from 2013 (in Spanish):

https://www.lacnic.net/innovaportal/file/543/1/manual-politicas-sp-2.0.pdf

In section 1.11, has exactly the same text:

“Los recursos de numeración de Internet bajo la custodia de LACNIC se deben 
distribuir a organizaciones legalmente establecidas en su región de servicio 
[COBERTURA] y para atender mayoritariamente redes y servicios que operan en 
dicha región.”

 

 

 

El 25/1/21 0:15, "Matthew Petach"  escribió:

 

 

 

On Sun, Jan 24, 2021 at 4:22 AM JORDI PALET MARTINEZ via NANOG 
 wrote:

[...] 

So, you end up with 2-3 RIRs allocations, not 5. And the real situation is that 
3 out of 5 RIRs communities, decided to be more relaxed on that requirement, so 
you don’t need actually more than 1 or may be 2 allocations. Of course, we are 
talking “in the past” because if we are referring to IPv4 addresses, you 
actually have a different problem trying to get them from the RIRs.

 

Hi Jordi,

 

I've adjusted the subject line to reflect the real thrust of this discussion.

 

You're right--if we're trying to get "new" allocations of IPv4 addresses, we've 
got bigger problems to solve.

 

But when it comes to IPv6 address blocks and ASNs, these questions are still 
very relevant.

 

And, going back to the original article that spawned the parent thread, the 
problem wasn't about companies requesting *new* blocks, it was about the usage 
of old, already granted blocks that were now being 

Re: Past policies versus present and future uses

2021-01-24 Thread John Sage

On 1/24/21 3:15 PM, Matthew Petach wrote:






Hi Jordi,

I've adjusted the subject line to reflect the real thrust of this 
discussion.




[edits Message Filters to include string "Past policies versus present 
and future uses" in Subject]


[selects folder "NANOG" in Thunderbird: All Folders]

[selects Tools --> Run Filters on Folder]

Bring it. My Trash ain't half full.

The question about moderators still holds.


And yes, for those wondering, I *have* unsubscribed about three or four 
times over -- what? -- a good fifteen years or more...



- John
--



Past policies versus present and future uses

2021-01-24 Thread Matthew Petach
On Sun, Jan 24, 2021 at 4:22 AM JORDI PALET MARTINEZ via NANOG <
nanog@nanog.org> wrote:
[...]

> So, you end up with 2-3 RIRs allocations, not 5. And the real situation is
> that 3 out of 5 RIRs communities, decided to be more relaxed on that
> requirement, so you don’t need actually more than 1 or may be 2
> allocations. Of course, we are talking “in the past” because if we are
> referring to IPv4 addresses, you actually have a different problem trying
> to get them from the RIRs.
>

Hi Jordi,

I've adjusted the subject line to reflect the real thrust of this
discussion.

You're right--if we're trying to get "new" allocations of IPv4 addresses,
we've got bigger problems to solve.

But when it comes to IPv6 address blocks and ASNs, these questions are
still very relevant.

And, going back to the original article that spawned the parent thread, the
problem wasn't about companies requesting *new* blocks, it was about the
usage of old, already granted blocks that were now being reclaimed.

Historically, ISPs have focused on ensuring their usage of IP space
reflected the then-current requirements at the time the blocks were
requested.  This action by Ron, well-intentioned as it is, raises a new
challenge for ISPs:  network numbering decisions that were made in the
past, which may have been done perfectly according to the guidelines in
place at the time the blocks were assigned, may later on violate *newly
added* requirements put in place by RIRs.  How many global networks
allocate manpower and time cycles to potentially renumbering portions of
their network each time a new policy is put in place at an RIR that makes
previously-conforming addressing topologies no longer conforming?
Historically, once addresses were granted by an RIR, and the exercise of
ensuring all the requirements were met, and the addresses were in place,
that was it; nobody went back every time a new policy was put in place and
re-audited the network to ensure it was still in compliance, and did the
work to bring it back into compliance if the new policy created violations,
because the RIRs generally didn't go back to see if new policies had been
retroactively applied to all member networks.

Ron's actions have now put every network on notice; it wasn't good enough
to be in compliance at the time you obtained your address space, you MUST
re-audit your network any time new policies are put into force by the RIR
in a region in which you do business, or your address space may be revoked
due to retroactive application of the new policy against addresses you have
already put into use.

This is a bigger deal that I think many people on the list are first
grasping.

We grow up accustomed to the notion that laws can't be applied
retroactively.  If you smoked pot last year, before it was criminalized,
they can't arrest you this year after a new law was passed for smoking it
before the law was passed.

In the DDoS-guard case, the address blocks in question seem to have been
granted by LACNIC nearly a decade ago back in 2013, under whatever policies
were in force at the time.  But they're being revoked and reclaimed based
on the policies that are in place *now*, nearly a decade later.

It sends a very clear message--it's not enough to be in compliance with
policies at the time the addresses are granted.  New policies can and will
be applied retroactively, so decisions you made in the past that were valid
and legal, may now be invalid, and subject you to revocation.  It's bad
enough when it's your own infrastructure that you have some control over
that you may need to re-number; woe to you if you assign address blocks to
*customers* in a manner that was valid under previous policy, but is no
longer valid under new policies--you get to go back to your customers, and
explain that *they* now have to redo their network addressing so that it is
in compliance, in order for *you* to be in compliance with the new
policies.  Otherwise, you can *all* end up losing your IP address blocks.

So--while I think Ron's actions were done with the best of intentions, I
think the fallout from those actions should be sending a chill down the
spine of every network operator who obtained address blocks under policies
in place a decade ago that hasn't gone back and re-audited their network
for compliance after ever subsequent policy decision.

What if one of *your* customers falls into Ron's spotlight; is the rest of
your network still in compliance with every RIR policy passed in the years
or decades since the addresses were allocated?  Are you at risk of having
chunks of your IP space revoked?

I know this sets a precedent *I* find frightening.  If it isn't scaring
you, either you don't run a network, or I suspect you haven't thought all
the way through how it could impact your business at some unforeseen point
in the future, when a future policy is passed.  :/

Thanks!

Matt