I’m dismayed that consultants would do that, but I guess there are no shortage 
of bad consultants out there.

I’ve been doing effectively SPARK for clients for a long time now (since well 
before IPv4 runout) and never sent a single client into the leasing realm 
(despite doing consulting for an IPv4 leasing organization).

I’ll wait for the proposal to be published as a draft policy before commenting 
further.

Owen


> On Sep 22, 2025, at 20:16, Preston Ursini via ARIN-PPML <[email protected]> 
> wrote:
> 
> Greetings all:
> 
> I am seeking community discussion on ARIN-prop-348, the SPARK proposal. SPARK 
> is intended to create a clear and straightforward entry point for new 
> organizations needing core Internet number resources. At present, a new 
> operator must make separate requests for an ASN, IPv4 under section 4.10, and 
> an IPv6 allocation. Each request has its own requirements, paperwork, and 
> fees. This complexity has real-world consequences: many small networks end up 
> turning to consultants who, in practice, often steer them into leasing IPv4 
> space instead of working directly with ARIN. That approach not only increases 
> costs for these new operators but also delays IPv6 deployment.
> 
> SPARK grew out of conversations with and feedback from small network 
> operators in the community. They want to do things “the right way” but face 
> too many barriers when first approaching ARIN. By creating a single, bundled 
> policy path, SPARK would make it far easier for them to start off on solid 
> footing, with an ASN, a /24 of IPv4 from the transition pool, and an IPv6 
> allocation that is sized for growth.
> 
> The benefit of defining SPARK explicitly in the NRPM is that it would give 
> ARIN staff a clear framework for implementation and provide new operators 
> with transparency and predictability. It would remove ambiguity, lower entry 
> costs, and encourage IPv6 adoption from day one. Without a policy like this, 
> the market incentives push new operators toward leasing arrangements that 
> solve their immediate IPv4 needs but do nothing to build long-term IPv6 
> readiness.
> 
> I may have confused the historic ASN issuance fee with the current transfer 
> fee when thinking through the costs, which highlights that ARIN’s fee 
> schedule could be presented more clearly on the website. That is probably 
> best addressed through the Consultation and Suggestion Process. The policy 
> question here, however, is whether we should formally establish SPARK as a 
> new allocation category in the NRPM, how it should be structured, and what 
> costs should be attached.
> 
> I would greatly appreciate community input on three fronts: where in the NRPM 
> this category should live, what fee model would be appropriate and fair, and 
> whether the proposed language around eligibility and resource sizes needs 
> adjustment.
> 
> Thank you in advance for your thoughts and feedback.
> 
> All the best,
> Preston Louis Ursini
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