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

[Michael Still]

I am not In favor of this proposal. I believe one of the major hurdles discussed previously was the inability for an individual to receive an ASN through any means other than via ARIN. Looking at the draft problem statement this is not actually made clear. I would propose a different policy be proposed with a different problem statement be written that directly addresses this issue. Something along the lines of "Current ARIN policy restricts the assignment of ASNs to be issued directly via ARIN. This policy aims to reduce this restriction such that LIRs/ISPs may reassign ASNs as part of their Internet services". I'm not a great wordsmith, this needs more thought. ARIN maintains its B2B nature and the burden for B2C transactions is placed at the LIR who would maintain the direct relationship with ARIN and be subject to its normal fee schedule. Then any individual can go to the LIR and procure the service, granted that they meet the normal technical requirements of assignment. To get an idea of what would need to be updated I asked an AI tool to see what would be a good starting point and it came up with this.

## Policies Requiring Update

To permit an LIR to assign both IP addresses and ASNs to individuals—effectively enabling individual subscribers to act as autonomous network operators—the following ARIN policies would need to be revised:

1. **Assignment and Allocation Distinctions:**

- Current language restricts "assignments" of resources to end-users who are *not* eligible to further sub-allocate or operate as fully independent resource holders. Policy must be updated to allow LIRs to assign IP space and ASNs to individual subscribers for their own autonomous use.

2. **Utilization and Justification Requirements:**

- Utilization requirements and technical justification must be modified to allow justification based on individual assignments, even for small-scale or residential use.

3. **ASN Allocation Policies:**

- Presently, ARIN issues ASNs directly to organizations/individuals who justify a unique routing policy, not to LIRs for indirect assignment. Policy must explicitly permit LIRs to assign (as opposed to reallocate) ASNs to their individual customers.

4. **Reassignment Registration and Privacy:**

- Reassignment rules must be clarified to provide streamlined SWIP or database documentation procedures and suitable privacy protections for individual resource holders.

### Key NRPM Sections Likely Affected

- Section 2.4: Definitions—LIR, ISP, End-User

- Section 4.2 & 4.3: Assignments/Reassignments to End-Users

- Section 6.5: IPv6 Allocations and Qualifications

- Section 6.5.5: Registration Requirements

- Section 7: Autonomous System Numbers (ASN)

## Sample Policy Update Language

Below is proposed amendment language. Use ARIN’s format for policy proposal clarity, traceability, and relevance:

### 1. NRPM Section 2.4 – Local Internet Registry (LIR)

**Current:**

> A Local Internet Registry (LIR) is an IR that assigns IP addresses to the users of the network services it provides...

**Update:**

> A Local Internet Registry (LIR) is an IR that assigns IP addresses and, when justified, Autonomous System Numbers (ASNs) to its users, including organizations or individuals, for use either as part of the LIR’s network or as independent, fully autonomous networks, as permitted by policy.

### 2. NRPM Section 4.3 & Section 6.5.8 – End-User Assignments

**Current:**

> End-users may only receive assignments for use within their internal networks and not for sub-delegation...

**Update:**

> LIRs may assign IP address space or ASNs to individual subscribers or organizations for their exclusive use, provided each subscriber demonstrates a bona fide technical need and agrees to ARIN’s utilization, stewardship, and reporting standards. Such assignments may be made for the purpose of customers operating independently routable networks.

### 3. NRPM Section 7 – Autonomous System Numbers

**Current:**

> ASNs are assigned directly by ARIN to organizations demonstrating a unique routing policy.

**Update:**

> ARIN may allocate ASNs to LIRs for assignment to their individual subscribers or customers who provide technical justification for a unique routing policy. LIRs must maintain records of assignments and make them available to ARIN upon request.

### 4. NRPM Section 6.5.5 – Registration

**Add:**

> LIRs assigning individual resources (IP addresses, ASNs) to end-user subscribers must register such assignments in the ARIN database, in accordance with customer privacy guidelines set forth in Section 3.3 and Section 4.2.3.7.3.2.

## Table: Policy Change Summary

| Area                | Current Policy Limit          | Required Change                       |

|---------------------|------------------------------|---------------------------------------|

| LIR Assignments     | Only to users of services    | To individuals as full resource holders|

| ASN Assignment      | Direct by ARIN to org/ind    | LIR may assign to customer with need  |

| Utilization         | Aggregated, per infra/user   | Explicit for individuals as networks  |

| Registration/SWIP   | Org-based, privacy rules     | Individual, robust privacy mechanisms |

## Considerations

- **Fee Plan:** Fee structure may also need adjustment for per-individual assignments.

- **Abuse & Stewardship:** Safeguards must ensure assignments are justified, efficiently utilized, and do not encourage resource hoarding or abuse.

**In summary:**

A comprehensive NRPM revision is necessary—spanning assignment eligibility, technical justification, ASN allocation, registration, and privacy—to permit LIRs to assign resources (IPs and ASNs) to individuals as autonomous operators, rather than only as users within a provider’s infrastructure.

Obviously more thought needs to go into this but this should help provide a base to start with to address this problem statement.

[ stillwaxin at gmail.com ~]$ cat .signature
cat: .signature: No such file or directory
[ stillwaxin at gmail.com ~]$ cat .disclaimer
All opinions are my own and do not represent any of my employer.
[ stillwaxin at gmail.com ~]$ cat .pronouns

He/Him

Sent via Superhuman ( https://sprh.mn/?vip=stillwaxin@gmail.com )

On Thu, Jul 10, 2025 at 7:26 PM, Elizabeth Goodson < 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
> (
> 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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