Hello,
I am very concerned at the way this draft policy has been revised and I
want to reiterate my opposition.
On 2026-08-20 11:37, ARIN wrote:
Problem Statement:
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.
The stated goal of this draft policy is to reduce harm to smaller
organizations in ARIN who have less than a /22 in region and require
some out of region use, as noted here.
Policy Statement:
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.
This part of the proposed policy fulfills that goal and I am not opposed
to it.
Out-of-Region Usage Justification may not be used to receive IPv4 address space
from the ARIN Waiting List (4.1.8), the Micro-allocation Pool (4.4), or the
Dedicated IPv4 Block to Facilitate IPv6 Deployment (4.10).
Any organization already on the Waiting List at the time this policy is
implemented will be exempted and shall remain eligible under the rules in
effect at the time of its placement on the Waiting List.
This part of the draft policy has nothing to do with the stated goal and
represents a fundamental change to ARIN's allocation policy, not an
adjustment to the minimum criteria for NRPM section 9 per the title and
stated goal of the draft policy. This should not be added as an
amendment to a policy.
We have entire policy proposals like ARIN-2025-8
<https://www.arin.net/participate/policy/drafts/2025_8/>, which only
prohibits the out-of-region use of NRPM section 4.10, that changes less
than this /amendment/ to the draft policy. In fact, if the current draft
of ARIN-2025-3 passes, it would render ARIN-2025-8 completely pointless
and all the objections to it moot.
Given the broad scope of this change and how it has /nothing/ to do with
the stated goal, this provision should be a *separate* policy so that
the community can properly participate and debate the merits of the
change. It should *not* be bundled as an *amendment* to a policy draft
whose name and stated goal has nothing to do with the provision. This
prevents the ARIN community from properly debating the policy change and
I cannot in good conscience support this.
Also, the portion that blanketly prohibits out-of-region usage
justifications for the ARIN Waiting List (section 4.1.8) has massive
implications. Unlike the reserved pools under section 4.4 and 4.10,
there are currently no limitations to the potential uses of ARIN
resources from the waiting list outside of those that apply to all IPv4
resources under NRPM section 4, only on the amount of space to ensure a
fair allocation. As such, users of the ARIN waiting list can currently
benefit from the full suite of services provided by ARIN.
Under this proposal, users of the ARIN waiting list (or any reserved
pools) will no longer be able to access the out-of-region justification,
meaning that the /only/ way to acquire new IPv4 resources for
out-of-region use would be through a section 8 transfer, which in
practice, means acquiring resources from a /third-party/ that is not the
ARIN member or ARIN itself. It means that the full suite of ARIN's
services will no longer be accessible without a third-party willing to
transfer resources, which in practice requires paying such parties large
sums of money. I find this change very concerning, as members will no
longer be able to access the full scope of ARIN's services by dealing
with ARIN itself.
Furthermore, the stated goal of the policy is to reduce "harm" of
smaller ARIN organizations who wishes to use resources out of region.
Recall under NRPM section 4.1.8 that:
Organizations which hold more than a /20 equivalent of IPv4 space in
aggregate (exclusive of special use space received under section 4.4
or 4.10) are not eligible to apply.
In effect, this means that all ARIN members who use the waiting list are
small organizations in the grand scheme of things. By prohibiting the
ability of such small organizations to use the waiting list, it forces
them to acquire IPv4 resources from the market, which is a lot more
costly than the waiting list. In essence, this policy /harms/ small
organizations that hold between a /22 and /20 of IPv4 space.
This harm is not necessary to accomplish the stated goal of this draft
policy. There is also, to my knowledge, no known influx of out-of-region
requests on the waiting list from ARIN organizations holding between a
/22 and /20 that justifies such an intervention. So why are we
penalizing this group of ARIN organizations when they have done no
wrong? For a policy that's supposed to reduce harm, it just harms a
/different/ group of ARIN members for no good reason.
In conclusion, the current formulation of Draft Policy ARIN-2025-3
contains provisions that have nothing to do with the stated goal of the
policy, and these provisions have wide-reaching consequences and inflict
direct and unnecessary harm on a different group of small ARIN members.
I firmly oppose this version of the policy.
Best regards,
Quantum
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