[arin-ppml] ARIN-2025-4: Resource Issuance to Natural Persons -- Request for Feedback

[Fernando Frediani]

Like William, I follow this rational as well.

Fernando

On 11/07/2025 16:26, William Herrin wrote:
> On Fri, Jul 11, 2025 at 9:42 AM Douglas Camin <doug at dougcamin.com> wrote:
>> consider the policy exclusively on the merits and not on cost.
>> If it’s good policy, it should be implemented and if not, it should
>> be abandoned. This keeps us focused on whether policy is sound
>> or not. A sound policy can be expensive, and an unsound one can be cheap.
> Hi Doug,
>
> Respectfully, good policy should not make ARIN a spendthrift. Good
> policy is cost-effective. That may not mean cheap, but it does mean
> cheaper than the reasonable alternatives. If, for example, the effect
> of this policy can be achieved by asking individuals to implement sole
> proprietorships and the cost of doing so is distinctly less than the
> cost of the proposed policy then the proposed policy would not be a
> good policy.
>
>
> Xavier -
>
> Speaking with my personal hat on, I don't know what a reasonable cost
> estimate would be. From the staff analysis, I gather that there are
> two types of cost here: direct and indirect.
>
> As far as I can figure, direct costs involve figuring out how to
> verify individual identities in every country where ARIN has
> registrants, figuring out what legal obligations exist for transacting
> with individuals vs. businesses in all ARIN-region countries,
> including taxes and privacy protections, etc. And then of course
> implementing procedures and training ARIN staff to do them.
>
> Indirect costs include legal risk where one of the governments decides
> ARIN isn't following its obligations to individuals and organizational
> risk where in some jurisdictions ARIN can't fulfil its other
> obligations due to a legal issue arising from individual registration.
> For example, suppose one of the localities where ARIN operates has
> privacy guarantees for individuals which prohibit ARIN from publishing
> those registrants' identities? HIPAA doesn't apply, but there are a
> bunch of countries here and even if they don't have a law today they
> could have one tomorrow. Business to business transactions, on the
> other hand, almost never have privacy guarantees except what's
> negotiated in the contract.
>
> Given the words ARIN staff used in the analysis, I would be surprised
> if the attributable cost of this policy was under $100k.
>
> By contrast, none of the policy's proponents have identified an
> ARIN-region jurisdiction in which the current solution, asking
> individuals to implement sole proprietorships, would be difficult or
> unduly expensive.
>
> It's not that ARIN won't grant IP addresses to individuals today,
> right? It's just that they have to jump through the extra hoop of
> declaring themselves a sole proprietorship and, in some cases, filing
> forms with the state government to that effect.
>
> Regards,
> Bill Herrin
>
>
>
> --
> William Herrin
> bill at herrin.us
> https://bill.herrin.us/
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