Hi Gerry,
Thanks to you and Doug Camin for shepherding the proposal. The use of “most” is based solely on my experience; an average of 2-3 per year. I would say 80% of those would rather just stick with ARIN. I do find it strange that you must have a /22 in region to be able to use section 9, but that there is no upper limit. If you can demonstrate that you need a /16 or larger out of region, you can be approved for it. I personally do not like limiting it to equal or less than current in-region use; several of those buyers needed blocks in multiple out of region locations but only had a /23 or /24 in ARIN. The very fact that they have a /24 in ARIN means they have not only a connection with the ARIN region, but a real and substantial presence here. So far they have all been US companies with locations in other areas. From: Gerry E.. George <[email protected]> Sent: Wednesday, March 18, 2026 1:10 PM To: Eddie Stauble <[email protected]> Cc: [email protected] Subject: Re: [arin-ppml] Request for Comment & Feedback: Draft Policy ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria Eddie, Thank you for the detailed explanation and background on the factors that led to the initiation of this process and proposal. It also provides helpful clarification and some insight regarding Matthew’s point: "Most of these recipients would much rather keep everything together in one ARIN account instead of having to go to another registry." Is the use of ‘most’ based on survey data or something else? To me, it seems important to determine whether or not there is a real quantified need. And also the point raised by Eric is worthy of further discussion: Should we rewrite the policy to allow any amount of out-of-region use so long as it is less than or equal to in-region use? (Obviously the usual needs-based rules also apply). Using more addresses/prefixes in-region than out-of-region seems like sufficient evidence of "real and substantial connection with the ARIN region" and is far better than arbitrary length-based rules. Let's keep the discussion going. Gerry E. George ICT Consultant and Business Solutions Architect; DigiSolv, Inc. [P.O. Box 1677, Castries, Saint Lucia] _____ Mobile: (758) 728-4858 / Int'l Office: (347) 450-3444 / Skype: DigiSolv Email: [email protected] <mailto:[email protected]> / LinkedIn: https://www.linkedin.com/in/gerrygeorge/ Please consider the environment before printing this email. Thank you. _____ From: "Eddie Stauble via ARIN-PPML" <[email protected] <mailto:[email protected]> > To: [email protected] <mailto:[email protected]> Sent: Wednesday, March 18, 2026 12:12:19 PM Subject: Re: [arin-ppml] Request for Comment & Feedback: Draft Policy ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria Sorry; I posted with the digest subject- first time poster! -----Original Message----- From: Eddie Stauble <[email protected] <mailto:[email protected]> > Sent: Wednesday, March 18, 2026 11:31 AM To: [email protected] <mailto:[email protected]> Subject: RE: ARIN-PPML Digest, Vol 249, Issue 16 I am the individual who made this proposal last year. I am an IPv4 broker and run into this issue on average 2-3 times a year. The reason I proposed this change is that I see the rule as discriminatory against the little guy; an injustice that I thought should be easy enough to remedy. The typical case is a buyer who has an ARIN account with at least a /24 but less than a /22. He needs addresses out of region. He cannot justify to ARIN since he does not have a /22 in region, so he has to go elsewhere. He would prefer to keep everything in ARIN, and does not want to sign up with RIPE or APNIC, though sometimes he does. His best option, and what I typically advise him to do, is to get a legacy block, usually from ARIN, though sometimes from APNIC, and register it in RIPE, which will incur no extra fees or dues. The irony is that RIPE requires him to demonstrate need when a block comes from ARIN. It does not matter to me personally whether the proposal is accepted; I sell an IPv4 block either way. I could also make the argument that I stand to gain more by selling an ARIN legacy block to a buyer registering it as legacy in RIPE as it is more complicated and takes more time. Before making this proposal, I wanted to research why a /22 was settled on, but could not find anything definitive. >From my research, it looks like out of region needs demonstration was first proposed by Terri Stumme in PROP 189 in May 2013, and was abandoned. The Second attempt was by David Farmer in PROP 192 in January 2014 and was abandoned. The third attempt was proposed by Christian Tacit in PROP 219 in May 2015. It became draft policy ARIN-2015-5, implemented July 2016. The AC Shepherds were Tina Morris and David Huberman. In looking back over the discussions of the proposals, there was a concern before ARIN ran out of addresses in September of 2015, that foreign entities would set up shell companies in the ARIN region, looking for free addresses. Now that ARIN is out, that fear is no longer valid. There was a fear of the additional expenses and complexity involved in verifying out of region use. Since the policy has been in effect for almost 10 years, ARIN should be able to weigh in with an opinion. It would be interesting to know whether ARIN ever denies out of region needs demonstration due to the lack of a /22 in region. There were also concerns expressed about unlimited openness to out of region use. Strangely, there is a lower limit on in-region use, but there is no upper limit to how much space can be used out of region, as long as you have a /22 in region. Has this been a problem? At the time I made the proposal I was not aware that one could use out of region use as needs demonstration to get a block from the waiting list. I do think that language should be added to prevent that, though probably complicating the issue. -----Original Message----- From: ARIN-PPML <[email protected] <mailto:[email protected]> > On Behalf Of [email protected] <mailto:[email protected]> Sent: Wednesday, March 18, 2026 10:49 AM To: [email protected] <mailto:[email protected]> Subject: ARIN-PPML Digest, Vol 249, Issue 16 Send ARIN-PPML mailing list submissions to [email protected] <mailto:[email protected]> To subscribe or unsubscribe via the World Wide Web, visit https://lists.arin.net/mailman/listinfo/arin-ppml or, via email, send a message with subject or body 'help' to [email protected] <mailto:[email protected]> You can reach the person managing the list at [email protected] <mailto:[email protected]> When replying, please edit your Subject line so it is more specific than "Re: Contents of ARIN-PPML digest..." Today's Topics: 1. Re: Request for Comment & Feedback: Draft Policy ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria (Matthew Cowen) ---------------------------------------------------------------------- Message: 1 Date: Wed, 18 Mar 2026 14:49:09 +0000 From: Matthew Cowen <[email protected] <mailto:[email protected]> > To: ARIN PPML <[email protected] <mailto:[email protected]> > Subject: Re: [arin-ppml] Request for Comment & Feedback: Draft Policy ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria Message-ID: <[email protected] <mailto:[email protected]> > Content-Type: text/plain; charset="utf-8" Mike, thank you for your response. I definately understand there are real costs involved, especially for small businesses, and potential losses to ARIN, so thanks for your example. However, my question still stands: is this a perceived problem or a real one that is quantified and supported by data in the ARIN community based on the statement that ?most of these recipients?? and actual use OOR? Doing policy for policy's sake seems like a waste of time. I have no stake either way, i just think its important to clarify that statement. Apologies, if I implied anything nefarious from the operators. That wasn?t my intention. I mentioned my local case as an illustration. On 18 Mar 2026, at 10:20, Mike Burns <[email protected] <mailto:[email protected]> > wrote: Hi Matthew, That?s a reasonable question. Considering the sizes at issue here, the costs of creating and maintaining an account at a foreign registry can be a high fraction of the IPv4 purchase cost, and so it would be unusual for any small ARIN account holder to prefer the costs and burdens of multiple registry accounts. The example examined the case of a small ARIN company requiring a /24 for overseas use, and being forced to register that /24 at RIPE, whose initial membership fee and ongoing fees for a /24 can quickly double the cost of that /24 to that small ARIN company, to say nothing of the administrative burdens or the loss of revenue to ARIN. This is an actual real example and we were forced by the policy to address the user?s need in this expensive manner. This policy would have avoided that. It is actually not unusual for larger companies to have RIR accounts at multiple registries and there is nothing nefarious about it. Regards, Mike From: ARIN-PPML <[email protected] <mailto:[email protected]%3cmailto:[email protected]> <mailto:[email protected]>> On Behalf Of Matthew Cowen via ARIN-PPML Sent: Wednesday, March 18, 2026 8:17 AM To: ARIN PPML <[email protected] <mailto:[email protected]%3cmailto:[email protected]> <mailto:[email protected]>> Subject: Re: [arin-ppml] Request for Comment & Feedback: Draft Policy ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria Quick question. The ?At issue? statement says: "Most of these recipients would much rather keep everything together in one ARIN account instead of having to go to another registry." Is the use of ?most? based on survey data or something else? To me, it seems important to determine whether or not there is a real quantified need. I?d support the overall idea of the policy (although not as currently proposed), but I think it should be unambiguous with respect to who and how many are demanding this, and also potential for abuse, as highlighted. There is a local case with Orange Cara?bes, the caribbean entity of Orange France, with a mish-mash of resources from ARIN/RIPE! Possibly other FWI/France operators too. On 17 Mar 2026, at 04:54, Gerry E.. George <[email protected] <mailto:[email protected]%3cmailto:[email protected]> <mailto:[email protected]>> wrote: Hello & Good day to PPML Community. As assigned shepherds, Matthew Wilder & myself are seeking feedback & comments on the current version of the Draft Policy ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria. I have summarized the key points below, but the full policy can be accessed here: https://www.arin.net/participate/policy/drafts/2025_3/ ARIN-prop-341 (ARIN-2025-3) - Change Section 9 Out Of Region Use Minimum Criteria In brief: Section 9 of the NRPM, Out of Region Use, requires organizations to use at least a /22 in the ARIN region before they can justify out of region use. This harms smaller organizations that have less than a /22 in region but do require some out of region use. Proposal: Modify the following text in Section 9: * FROM: IPv4: At least a /22 used in region. * TO: IPv4: At least a /24 used in region. RESULT: Out of region use of ARIN registered resources are valid justification for additional number resources, provided that the applicant has a real and substantial connection with the ARIN region which applicant must prove (as described below) and is using the same type of resources (with a delegation lineage back to an ARIN allocation or assignment) within the ARIN service region as follows: * IPv4: At least a /24 used in region * IPv6: At least a /44 used in region * ASN: At least one ASN present on one or more peering sessions and/or routers within the region At issue: When a company needs address space outside of the ARIN region without at least a /22 in region, they go to RIPE and acquire either PI or Legacy space (the least expensive option), often acquiring the space from ARIN sources. In the case of an inter-regional ARIN to RIPE transfer, RIPE does require the recipient to demonstrate need, as required by ARIN. ARIN is losing registration of the block and annual fees, as well as the recipient transfer fee. Most of these recipients would much rather keep everything together in one ARIN account instead of having to go to another registry. While there are no material legal issues, it is anticipated that this change in policy would significantly increase the volume of IPv4 waitlist requests and could lead to an increase to staff ticket workload. Because the policy requirements for an organization to justify an initial /24 are generally straightforward to meet, it is expected that more organizations may request a /24 primarily to qualify for additional ARIN-issued IPv4 addresses for out-of-region use. It is expected that this would result in more ARIN IPv4 space being used out of region. Concern regarding possible abuse of the reduced requirement in order to obtain ARIN resources, particularly for blocks larger than the minimum (/24) for OOR use. Considerations: - How much of an issue could this be? Does it matter to the community? - Should there be a requirement for the OOR use be not more/greater than the in-ARIN region use? - Can this unfavorably impact companies having more growth OOR, and drive them to other RIRs and away from ARIN in such instances? - Is there a probability for potential abuse via the Waitlist, and if so, should there be consideration for limitations to the designated region use for 4.1.8. requests? - Is the "real and substantial connection" requirement in Section 9 be sufficient to prohibit or reduce the potential for abuse? Questions: Are you in support of the policy? Are there any additional issues which should be considered? Should the AC continue working on the policy as written? And remember, the ARIN public policy process runs on positive consensus not silent assent, so please weigh in. We look forward to your engagement. Thanks. Gerry E. George ICT Consultant and Business Solutions Architect; DigiSolv, Inc. [P.O. Box 1677, Castries, Saint Lucia] ________________________________ _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected] <mailto:[email protected]%3cmailto:[email protected]> <mailto:[email protected]>). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] <mailto:[email protected]%3cmailto:[email protected]> <mailto:[email protected]> if you experience any issues. ? My best/Cordialement, Matthew Cowen ? My best/Cordialement, Matthew Cowen -------------- next part -------------- An HTML attachment was scrubbed... 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