[arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement

Chris Woodfield chris at semihuman.com
Wed Sep 22 16:56:23 EDT 2021 

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 <mike at 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 <chris at semihuman.com> 
> Sent: Wednesday, September 22, 2021 4:25 PM
> To: Mike Burns <mike at iptrading.com>; PPML <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement
>  
>  
> 
> 
>> On Sep 22, 2021, at 1:12 PM, Mike Burns <mike at iptrading.com <mailto:mike at 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-bounces at arin.net <mailto:arin-ppml-bounces at arin.net>> On Behalf Of Mike Burns
>> Sent: Wednesday, September 22, 2021 11:50 AM
>> To: 'Chris Woodfield' <chris at semihuman.com <mailto:chris at semihuman.com>>; 'PPML' <arin-ppml at arin.net <mailto:arin-ppml at 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 <chris at semihuman.com <mailto:chris at semihuman.com>> 
>> Sent: Wednesday, September 22, 2021 11:33 AM
>> To: PPML <arin-ppml at arin.net <mailto:arin-ppml at arin.net>>
>> Cc: Owen DeLong <owen at delong.com <mailto:owen at delong.com>>; Mike Burns <mike at iptrading.com <mailto:mike at 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 <mike at iptrading.com <mailto:mike at 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-bounces at arin.net <mailto:arin-ppml-bounces at arin.net>> On Behalf Of Chris Woodfield
>>> Sent: Tuesday, September 21, 2021 9:21 PM
>>> To: Owen DeLong <owen at delong.com <mailto:owen at delong.com>>
>>> Cc: PPML <arin-ppml at arin.net <mailto:arin-ppml at arin.net>>
>>> Subject: Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement
>>>  
>>>  
>>>> On Sep 21, 2021, at 10:22 AM, Owen DeLong <owen at delong.com <mailto:owen at 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 <chris at semihuman.com <mailto:chris at 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 <info at arin.net <mailto:info at 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
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>>>>> 
>>>>>  
>>>>> _______________________________________________
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