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 <[email protected]> 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 <[email protected]> > Sent: Wednesday, September 22, 2021 4:25 PM > To: Mike Burns <[email protected]>; PPML <[email protected]> > Subject: Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement > > > > >> On Sep 22, 2021, at 1:12 PM, Mike Burns <[email protected] >> <mailto:[email protected]>> 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 <[email protected] >> <mailto:[email protected]>> On Behalf Of Mike Burns >> Sent: Wednesday, September 22, 2021 11:50 AM >> To: 'Chris Woodfield' <[email protected] <mailto:[email protected]>>; >> 'PPML' <[email protected] <mailto:[email protected]>> >> 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 <[email protected] <mailto:[email protected]>> >> Sent: Wednesday, September 22, 2021 11:33 AM >> To: PPML <[email protected] <mailto:[email protected]>> >> Cc: Owen DeLong <[email protected] <mailto:[email protected]>>; Mike Burns >> <[email protected] <mailto:[email protected]>> >> 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 <[email protected] >>> <mailto:[email protected]>> 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 <[email protected] >>> <mailto:[email protected]>> On Behalf Of Chris Woodfield >>> Sent: Tuesday, September 21, 2021 9:21 PM >>> To: Owen DeLong <[email protected] <mailto:[email protected]>> >>> Cc: PPML <[email protected] <mailto:[email protected]>> >>> Subject: Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit >>> Requirement >>> >>> >>>> On Sep 21, 2021, at 10:22 AM, Owen DeLong <[email protected] >>>> <mailto:[email protected]>> 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 <[email protected] >>>>> <mailto:[email protected]>> 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 <[email protected] <mailto:[email protected]>> >>>>>> 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 ([email protected] >>>>>> <mailto:[email protected]>). >>>>>> 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 [email protected] <mailto:[email protected]> if you experience >>>>>> any issues. >>>>> >>>>> >>>>> _______________________________________________ >>>>> ARIN-PPML >>>>> You are receiving this message because you are subscribed to >>>>> the ARIN Public Policy Mailing List ([email protected] >>>>> <mailto:[email protected]>). >>>>> 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 [email protected] <mailto:[email protected]> if you experience any >>>>> issues.
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