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

[Douglas Camin]

Bill -

A​t such an early stage of the policy process, I think it’s more productive to stay focused on whether the policy is technically sound and good. There are lots of other gateposts to pass to understand whether it would cost a fortune or blow up everything else. The community can ask staff through the shepherds to find out more of that type of information so it can be formally included if that’s what the community wants.

Hope that helps -


Doug








--

Douglas J. Camin

ARIN Advisory Council

doug at dougcamin.com

From: William Herrin <bill at herrin.us>
Date: Friday, July 11, 2025 at 3:27 PM
To: Douglas Camin <doug at dougcamin.com>
Cc: arin-ppml <arin-ppml at arin.net>
Subject: Re: [arin-ppml] ARIN-2025-4: Resource Issuance to Natural Persons -- Request for Feedback

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://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fbill.herrin.us%2F&data=05%7C02%7C%7C3093b9458d6a464b0df908ddc0b0e707%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C638878588200124523%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=lvjJiD4QmQdKT%2BHV0BI8Z2NKnvkxyH6YjRj%2BDxhER9Q%3D&reserved=0<https://bill.herrin.us/>
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