I'm not sure what benefit you forsee by running a COW filesystem (ZFS) on a COW 
array (NetApp). 

Back to regularly scheduled programming: I still say you should let ZFS manage 
JBoD type storage. I can personally recount the horror of relying upon an 
intelligent storage array (EMC DMX3500 in our case.) We had in flight data 
corruption that EMC faithfully wrote just like NetApp would in your case. 
Everybody is assuming that corruption or data loss occurs only on disks, it can 
happen everywhere. In a datacenter SAN you've so many more paths that can 
introduce data corruption. Hence the need for ensuring data integrity closest 
to the use of data, namely ZFS. ZFS will not stop alpha particle induced memory 
corruption after data has been received by server and verified to be correct. 
Sadly I've been hit with that as well.
 
 
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