Good evening,
I would also like to express my strong opposition to the revised version
of ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria as
written.
The original version of this proposal, along with its title and stated
purpose, was to reduce the burden on smaller ARIN members for
out-of-region justification of new address space by reducing the
out-of-region justification requirement from a /22 to a /24. This
change, I support, as I believe that requiring small organizations to
acquire a /22 of address space through some means before they may
request out-of-region space is impractical.
Unfortunately, the amended version of the proposal wildly expands its
scope and transforms it into a policy proposal I cannot support. The
revised version of this 'change out of region eligibility criteria'
proposal adds large additional constraints to other unrelated components
of the NRPM and number request process. More specifically, per my
reading, it removes out-of-region use entirely as justification for
*ANY* IPv4 resources requested directly from ARIN and leaves open only
the 'transfer market'.
I feel that this amendment to the proposal is difficult to reconcile
with the PDP principle of enabling fair and impartial number resource
administration, under which the Advisory Council must evaluate this
draft. Although many state that the 'transfer market' is a valid and
feasible way to obtain addresses, I believe some are failing to consider
that the 'transfer market' is not a practical option for the types of
organizations that this proposal purports to support. This is true for a
number of reasons, primarily that IPv4 addresses are expensive. For many
small businesses, being told to find $10k or more to spend on the
transfer market is not a practical answer, and this amendment would
leave them no alternative by closing the standard allocation path entirely.
To use the waitlist as an example, I do not think ARIN should make it
its policy to categorically exclude a group of operators like myself
(who are willing to work through the waitlist allocation process and
wait for a block to be available) from internet resources that they have
demonstrated a need for, nor should ARIN be essentially forcing this
group to pay exorbitant prices on the private market. The waitlist is
also in effect exclusively used by 'small networks' due to its size
restrictions and long wait times. I suspect that many of those on the
list with out-of-region use cases would be unreasonably harmed by this
change, whereas larger businesses or larger networks that may or may not
be eligible for the waitlist in the first place would have no issue
ponying up $10k for an out-of-region-approved block. I do not see how
excluding a specific subset of entities operating within ARIN's service
region from direct registry service can be described as fair and
impartial administration.
This proposal also makes the unprecedented change of restricting
waitlist eligibility on the basis of the *intended use* of the addresses
requested. Historically, every codified restriction on waitlist requests
has been based on who the applicant is or what resources they already
hold. None have been based on the purpose of the requested addresses, or
how that organization may choose to utilize them within their
infrastructure. My interpretation of the waitlist's purpose is that it
serves as a catch-all: if you do not qualify for one of the
special-purpose pools, you may still document your need and wait. This
proposal would create the first category of need that ARIN policy
expressly designates as valid justification under Section 9, but for
which ARIN will issue no addresses under any circumstances.
I understand that out-of-region use is at best a secondary priority for
ARIN. However, Section 9 already requires a real and substantial
connection to the ARIN service region, so the organizations affected
here are ARIN's own constituents, not entities shopping for a registry.
Directing them to another RIR is not a costless redirection: obtaining a
single /24 from the RIPE NCC, for example, currently requires
establishing and indefinitely funding an LIR account at roughly EUR
1,800 per year plus a sign-up fee, for a multi-year wait and a one-time
allocation, for a need they can *already* document to their current RIR
(ARIN).
This policy would also, in effect, create a distinction in the service
offered by ARIN based purely on the amount of resources (money) the ARIN
member is willing to expend. By completely closing direct IPv4
allocations for out-of-region use, those ARIN members who have
completely legitimate reasons to request space from ARIN for use outside
the ARIN service region would only receive registry services from ARIN
if they were willing to expend large amounts of money with an unrelated
third party. This seems like a strange and concerning system to
introduce in a proposal intended to help smaller networks.
The amended proposal would also result in the policy directly
contradicting itself, at least to a reader without a legal background
such as myself (emphasis and cuts mine):
On 8/20/26 11:37 AM, ARIN wrote:
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:
[...]
***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).***
Although I understand that ARIN policy additionally requires
justification for transferred-in resources, I find the amended policy to
be confusing and contradictory, as it states that out-of-region use is
justification but then excludes all ways of directly receiving an
allocation from ARIN for a specific class of resources (IPv4). In my
eyes, this means that it is in fact not valid justification. If the
community wishes to proceed with this specific policy (of no longer
allowing out-of-region direct allocations of IPv4 resources to ARIN
members), then I would suggest a rewording is in order, as the policy
provides a 'justified use case' for which ARIN bars direct allocations.
To conclude, as others have mentioned, the amended version of this
proposal would, in my opinion, be far better as a set of separate,
narrowly tailored policy proposals, such as the ARIN-2025-8 draft policy
that already exists, rather than as a 'five birds with one stone' policy
proposal that claims to help the very people that this amended proposal
would harm. This amendment essentially creates two tiers of IPv4
addresses within ARIN policy, which is a much broader and more complex
change than the original text of this proposal, and presents its own set
of challenges and concerns that should be discussed separately.
Although I would have supported this proposal as it was originally
written, I cannot support the amended version due to the harm it would
directly cause to small business network operators like myself, and I
must therefore oppose this proposal as it is written.
Warmly,
-T
_______________________________________________
ARIN-PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List ([email protected]).
Unsubscribe or manage your mailing list subscription at:
https://lists.arin.net/mailman/listinfo/arin-ppml
Please contact [email protected] if you experience any issues.
