[arin-ppml] ARIN-2025-4: Resource Issuance to Natural Persons -- Request for Feedback (John Curran)
Preston Ursini
preston at thefirehorn.com
Fri Jul 11 17:10:19 EDT 2025
I firmly believe that financial consideration will need to be a factor in this, and that in this stage of the discussion the focus should be on finding real world impacts and scenarios of where Individuals were:
A: Unable to become sole proprietors and why
B: Finding out which jurisdictions make registering as a sole proprietor untenable for Individuals that would otherwise be eligible for numbering assets.
ARIN has already expended some efforts in the initial assessment and even published articles on this very issue: https://www.arin.net/blog/2025/05/28/individual-requests/
ARINs interpretation of who is and isn’t a “business” may solve many of these scenarios posed by those looking for numbering assets. It also appears that ARIN has started doing some leg work on this page: https://www.arin.net/resources/guide/request/individual_request on listing jurisdictions and how they handle these types of classifications.
I believe community feedback on points A and B are paramount before ARIN expend too many resources on financial studies; if the problem ends up being solved for most through these publications and via policy interpretation/impact vs policy change, then we could ask ourselves whether a larger scale impact on ARIN be worth it?
One issue is that Individuals that have been disenfranchised by this policy do not have a strong voice within these discussions because by their very virtue of being Individuals, they’ve been excluded from participation; so building case studies is at the very least challenging at best.
Preston Ursini
> On Jul 11, 2025, at 3:47 PM, arin-ppml-request at arin.net wrote:
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> 1. Re: ARIN-2025-4: Resource Issuance to Natural Persons --
> Request for Feedback (John Curran)
>
>
> ----------------------------------------------------------------------
>
> Message: 1
> Date: Fri, 11 Jul 2025 20:47:50 +0000
> From: John Curran <jcurran at arin.net>
> To: Martin J Hannigan <hannigan at gmail.com>
> Cc: David Farmer <farmer at umn.edu>, arin-ppml <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] ARIN-2025-4: Resource Issuance to Natural
> Persons -- Request for Feedback
> Message-ID: <2A92EBEE-A1FD-4E6F-ADBC-53644453B9B6 at arin.net>
> Content-Type: text/plain; charset="utf-8"
>
> 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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> --
> ===============================================
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