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

Fri Jul 11 16:47:50 EDT 2025

Marty -

We will work to prepare an estimate of the likely costs, but recognize that this will be an somewhat uninformed estimate as many of the implications to the organization practices will require outside parties (e.g. audit/taxation expertise) to fully assess the implications - as noted in the early staff and legal review that was conducted:  https://www.arin.net/participate/policy/drafts/2025_4/#staff-and-legal-review-3-june-2025)

(In addition, we cannot readily determine whether ARIN changing from a business-to-business entity to an one that offers services to consumers will have any impact to ARIN business practices for our existing customers – such as with regards to ARIN’s privacy policy, GST/HST/PST tax treatment, etc. – without substantial investment that would not be appropriate at this early stage in policy development.)

Thanks,
/John

John Curran
President and CEO
American Registry for Internet Numbers

On Jul 11, 2025, at 3:46 PM, Martin Hannigan <hannigan at gmail.com> wrote:

A ballpark cost estimate would be helpful.

On Fri, Jul 11, 2025 at 15:42 David Farmer via ARIN-PPML <arin-ppml at arin.net<mailto:arin-ppml at arin.net>> wrote:
Doug,

While I agree that expenses should not be the first consideration when evaluating policy, at least usually.

Nevertheless, the staff and legal review for this policy, dated June 3rd, warns, "Proper implementation will require significant investment to determine the full extent of the legal, operational, and compliance adaptations necessary, as well as determining resulting implementation cost."

That raises a serious question about what this policy would cost, and not just the simple expense of it, but also the legal, operational, and compliance consequences to the organization. Those can be boiled down to expenses, but from a policy perspective, those are more than just expenses, and the consideration of those consequences becomes central to evaluating this policy.

Thanks

On Fri, Jul 11, 2025 at 1:44 PM Douglas Camin <doug at dougcamin.com<mailto:doug at dougcamin.com>> wrote:
Scott -

I think the intent is to suggest that the community first focus on the merits of the policy ahead the costs. This does not mean cost is never a consideration, but at this juncture - this draft policy is brand new and only received an early staff and legal because of its legal implications - the questions to the community revolve around “is this good policy or not."

Hope that helps -

Doug

--
Douglas J. Camin
doug at dougcamin.com<mailto:doug at dougcamin.com>
From: Scott Leibrand <scottleibrand at gmail.com<mailto:scottleibrand at gmail.com>>
Date: Friday, July 11, 2025 at 1:31 PM
To: arin-ppml <arin-ppml at arin.net<mailto:arin-ppml at arin.net>>, Douglas Camin <doug at dougcamin.com<mailto:doug at dougcamin.com>>
Subject: Re: [arin-ppml] ARIN-2025-4: Resource Issuance to Natural Persons -- Request for Feedback

I wholeheartedly disagree. If the benefits of the policy change don’t exceed the costs, it’s not good policy. I’m not convinced we haven’t already wasted more of our collective time discussing this policy than will ever be saved by the small number of individuals who’d benefit from it (those who can’t easily apply as sole proprietors).

-Scott
On Jul 11, 2025 at 9:43 AM -0700, Douglas Camin <doug at dougcamin.com<mailto:doug at dougcamin.com>>, wrote:

Xavier -

Appreciate the feedback and question. When considering policy, it’s encouraged to 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.

Hope that helps, though I know it doesn’t directly answer your question - we’d love to get your feedback on your views on what we should do with the policy.

Thanks!

Doug

--
Douglas J. Camin
ARIN Advisory Council
doug at dougcamin.com<mailto:doug at dougcamin.com>

From: ARIN-PPML <arin-ppml-bounces at arin.net<mailto:arin-ppml-bounces at arin.net>> on behalf of Xavier via ARIN-PPML <arin-ppml at arin.net<mailto:arin-ppml at arin.net>>
Date: Thursday, July 10, 2025 at 8:33 PM
To: Elizabeth Goodson <elizabeth.goodson at gmail.com<mailto:elizabeth.goodson at gmail.com>>
Cc: ARIN-PPML at arin.net<mailto:ARIN-PPML at arin.net> <ARIN-PPML at arin.net<mailto:ARIN-PPML at arin.net>>
Subject: Re: [arin-ppml] ARIN-2025-4: Resource Issuance to Natural Persons -- Request for Feedback

My feedback on this policy depends on what the "implementation cost" (referenced in the last paragraph of the Legal Review section) will be. Making it easier to access resources is probably worth $10,000 but is probably not worth $250,000, IMO. Do we have a ballpark estimate?

Thank you,
Xavier Clark

On Thursday, July 10th, 2025 at 7:27 PM, Elizabeth Goodson <elizabeth.goodson at gmail.com<mailto:elizabeth.goodson at gmail.com>> wrote:
Hello PPML,

I'm shepherding this policy along with Doug Camin. We're seeking direction from the community as to how the AC should proceed with this policy. There was robust conversation on PPML in late May and early June, which tapered off quickly after the ARIN Staff and Legal analysis was published.

https://www.arin.net/participate/policy/drafts/2025_4/#staff-and-legal-review-3-june-2025

Should we
- abandon this policy,
- accept this policy as written, or
- continue to revise this policy?

We appreciate your feedback.

Thanks,
Liz Goodson

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