[arin-ppml] Draft Policy ARIN-2025-4: Resource Issuance to Natural Persons
David Farmer
farmer at umn.edu
Sun Jun 1 19:36:57 EDT 2025
Actually I’m drawing a distinction between natural persons operating a
business and natural persons not operating a business, I’m simply using
hobbyists as clear example of that latter group. Hobbyist is about as far
away from operating as a business I can think of.
To a certain extent, ARIN’s current practice already includes natural
persons operating a business, but excludes natural persons not operating a
business.
If we intend natural person in policy statement to include those not
operating a business, like hobbyists, that is a change to current
practices. Which is fine with me, but we should be explicit that this
change is intentional. Maybe add “nature persons acting in any capacity” to
the text or in the discussion make it clear natural person intentionally
includes all natural persons, those operating a business or not, including
hobbyists.
===============================================
David Farmer Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE Phone: 612-626-0815
Minneapolis, MN 55414-3029 Cell: 612-812-9952
===============================================
On Sun, Jun 1, 2025 at 16:24 John Santos <john at egh.com> wrote:
> You seem to be drawing a distinction between natural persons who are
> hobbyists and those who are not. Is that a distinction without a
> difference?
>
> Should ALL hobbyists who otherwise meet the criteria be allowed to acquire
> Internet number resources, or should there be additional restrictions
> beyond those that apply to any business, sole proprietorship, partnership,
> government agency, NGO, educational institution, etc.?
>
> Why should someone who meets all the requirements but is NOT a hobbyist be
> denied access to resources?
>
> Could this all be resolved by adding additional requirements that
> automatically pertain to anything currently recognized as an "organization"
> by ARIN, but do not necessarily apply to all natural persons?
>
> I think there is an unstated major premise in this argument, unstated by
> both sides.
>
> I don't know what that premise is. I think I may be missing an important
> point.
>
> The only way to determine, as far as I can tell, who is a hobbyist and who
> is not, is if that person self-identifies as a hobbyist. If so, anyone can
> do that. It is a meaningless legal distinction, and I support the proposal
> as written.
>
> But maybe the unstated premise, if it were stated, might make clear why
> people are concerned about this. Maybe there should be some additional
> requirement beyond simply agreeing to the terms of the RSA? What are those
> requirements that would apply to a natural person, but either do not apply
> to an organization or are implicitly implied when an organization signs the
> RSA? Why isn't simply signing the RSA, abiding by its terms and paying any
> fees, sufficient?
>
> -- John
> On 6/1/2025 4:10 PM, David Farmer via ARIN-PPML wrote:
>
> Thank you, Owen. My original point was that, as written, allowing natural
> persons without any language that restricts them to operating a business
> effectively allows hobbyists. As I said later in the thread, part of me is
> good with that; however, if we actaully intend hobbyists to be included,
> and at least some people supporting the policy, do intend hobbyists to be
> included, we need to be explicit about that being our intent, which the
> current text is not. So, with the current text, hobbyists are included as
> natural persons, but as written, that appears to be an unintended
> consequence. Therefore, we either need to be abundantly clear that we
> intend hobbyists to be included, or we need language restricting natural
> persons to operating a business if we don't intend hobbyists to be included.
>
> In my original post, I focused on the latter part, providing language
> restricting natural persons to operating a business, and somehow, I lost
> the first part about being abundantly clear that we intend hobbyists to be
> included. Sorry about that.
>
> Thanks.
>
> On Sun, Jun 1, 2025 at 1:03 PM Owen DeLong via ARIN-PPML <
> arin-ppml at arin.net> wrote:
>
>> +1
>>
>> There are those that would consider my network in the “hobbyist”
>> category. I’d argue that David’s use of the term here is the most vague
>> part of the discussion in that there’s no clear line to differentiate
>> hobbyist from business.
>>
>> My network has ARIN resources and RIPE resources (the latter being the
>> result of a convoluted need to resolve issues created by the ARIN board).
>> Those resources are registered to “Owen DeLong and Family”. There are no
>> corporations that I consider family members, so for better or worse, those
>> resources were issued to natural persons.
>>
>> While ARIN has consistently claimed that resources were always issued to
>> organizations, not individuals, the meaning of that statement has morphed
>> over the years without actual policy changes to support its evolution.
>> Originally, it was intended to clarify that regardless of who the
>> registered POCs on the resource were, the resource was registered to the
>> ORG. For several years now, it’s been used as a cudgel to deny issuing
>> resources to those who apply as individuals without first creating some
>> form of organizational facade and more recently ARIN has started using it
>> to require that facade be some form of legal business entity.
>>
>> I support the policy as written and believe that rather than anything
>> being snuck in through vague language, the policy clarifies prior policy
>> intent which staff has drifted away from over many years of evolution.
>>
>> Owen
>>
>>
>> On May 30, 2025, at 11:40, Matt Erculiani <merculiani at gmail.com> wrote:
>>
>>
>> I’ll double down.
>>
>> What threat does a hobbyist pose to the global routing or Internet
>> numbers systems?
>>
>> Presumably someone going through this process isn’t your average
>> home-labber; what’s the harm in them having a block of their own unique
>> IPv6 if they pay the bill on-time? There are plenty of tunnel services that
>> make this a viable option these days.
>>
>> I’m prepared to be eaten alive for the suggestion.
>>
>> Matt Erculiani
>>
>>
>> On Fri, May 30, 2025 at 12:30 Tyler O'Meara via ARIN-PPML <
>> arin-ppml at arin.net> wrote:
>>
>>> Hi Ben,
>>>
>>> I don't think a categorical exclusion for "hobbyists" (whatever that
>>> actually
>>> means in practice) is necessary or useful. The relevant sections for
>>> resource
>>> justifications already require operating an actual network, so someone
>>> (or
>>> organization) who wanted to come in and get IP addresses without running
>>> a
>>> network would already be excluded. I suppose theoretically they could
>>> request a
>>> single ASN, but if they're not planning on actually running a network
>>> that ASN
>>> is worthless to them anyways.
>>>
>>> I'll also note that not all valid use cases for acquiring resources
>>> necessitate
>>> participating in global routing, although I doubt those use cases are
>>> particularly relevant to natural persons. We should be careful not to
>>> accidentally remove these use cases however.
>>>
>>> Tyler
>>>
>>> On Fri, 2025-05-30 at 11:12 -0700, Ben Shapiro wrote:
>>> > Thank you David, for the thoughtful revisions and to ARIN staff for
>>> > progressing this discussion.
>>> >
>>> > As someone involved in the operation of a small-to-medium Internet
>>> Exchange
>>> > Point (IXP), I’d like to offer a complementary perspective from the
>>> > interconnection and community network operator ecosystem.
>>> >
>>> > IXPs—particularly regional, volunteer-run, or lightly incorporated
>>> > ones—frequently interface with a range of participants, including
>>> small ISPs,
>>> > research networks, community fiber projects, and technically capable
>>> > individuals who operate networks that meaningfully contribute to
>>> regional
>>> > interconnection and resiliency. Some of these operators do not have
>>> formal
>>> > corporate structures, yet they are deeply engaged in the technical and
>>> > operational requirements of network management and peering. From our
>>> vantage
>>> > point, the exclusion of natural persons from eligibility can pose an
>>> > artificial barrier that does not align with real-world routing and
>>> > interconnection practices.
>>> >
>>> > While I agree with David that natural persons operating legal
>>> businesses
>>> > should unquestionably be considered valid organizations, I also see
>>> > operational value in supporting natural persons who:
>>> >
>>> > * Operate autonomous systems used in peering environments;
>>> > * Maintain IPv6 prefixes with global routing visibility;
>>> > * Support last-mile, experimental, or community-focused efforts.
>>> >
>>> > Such actors are already required to justify their needs under existing
>>> ARIN
>>> > policies. Adding verification of identity and residency, as the draft
>>> > suggests, provides accountability without unduly excluding legitimate
>>> network
>>> > operators who do not or cannot register as a business.
>>> >
>>> > From the IXP perspective, clarity is important. I support revising the
>>> policy
>>> > language to explicitly differentiate:
>>> >
>>> > 1. Hobbyists with no operational network or intent to participate
>>> in global
>>> > routing (not eligible),
>>> > 2. Natural persons operating a routable, justified network
>>> (eligible), and
>>> > 3. Natural persons operating a legal business (clearly eligible).
>>> >
>>> > A possible refinement might be:
>>> >
>>> > > An organization is a company, corporation, partnership, sole
>>> proprietorship,
>>> > > government agency, non-profit entity, educational institution, or
>>> natural
>>> > > person who operates a network consistent with ARIN’s resource
>>> justification
>>> > > requirements and, where applicable, provides verification of
>>> identity and
>>> > > residency. A natural person solely acting as a hobbyist is not
>>> considered an
>>> > > organization.
>>> >
>>> > This language allows for policy consistency while acknowledging that
>>> technical
>>> > legitimacy can come in many forms.
>>> >
>>> > Thank you for the opportunity to comment. I support further refinement
>>> of this
>>> > proposal and appreciate ARIN’s responsiveness to community input.
>>> >
>>> > Best regards,
>>> > Ben
>>> >
>>> >
>>> > BEN SHAPIRO
>>> > President | Willamette Internet Exchange
>>> > president at thewix.net | (541) 255-0280
>>> >
>>> >
>>> > On May 30, 2025 at 10:59:00 AM, David Farmer via ARIN-PPML
>>> > <arin-ppml at arin.net> wrote:
>>> >
>>> > >
>>> > > I do not support the policy as written. As written, it is unclear
>>> whether
>>> > > natural persons not conducting business and acting solely as
>>> hobbyists are
>>> > > excluded. However, natural persons operating businesses in their own
>>> name
>>> > > should be considered valid organizations.
>>> > >
>>> > > Organizations must;
>>> > > 1. Operate as legal businesses within the ARIN service region.
>>> > > 2. Operate a network within the ARIN service region with Internet
>>> number
>>> > > resources allocated by or registered with ARIN.
>>> > > 3. Meet other policy or eligibility criteria.
>>> > > From a policy perspective, the first two are fundamental criteria
>>> that must
>>> > > be included in the definition of an organization.
>>> > >
>>> > > I suggest the following revision to the policy text;
>>> > >
>>> > > > 2.x Organization
>>> > >
>>> > > > An organization is a company, corporation, partnership, sole
>>> > > > proprietorship, government agency, non-profit entity, educational
>>> > > > institution, or natural person operating as a legal business
>>> within the
>>> > > > ARIN service region. It must also operate a network within the ARIN
>>> > > > service region with Internet number resources allocated by or
>>> registered
>>> > > > with ARIN and meet other policy or eligibility criteria.
>>> > >
>>> > > I also want to point out the recent blog post by ARIN Staff about
>>> this
>>> > > subject.
>>> > > https://www.arin.net/blog/2025/05/28/individual-requests/
>>> > >
>>> > > Thanks.
>>> > >
>>> > > On Tue, May 20, 2025 at 12:33 PM ARIN <info at arin.net> wrote:
>>> > > > On 15 May 2025, the ARIN Advisory Council (AC) accepted
>>> ARIN-prop-343:
>>> > > > Resource Issuance to Natural Persons as Draft Policy.
>>> > > >
>>> > > > Draft Policy ARIN-2025-4 is below and can be found at:
>>> > > >
>>> > > > https://www.arin.net/participate/policy/drafts/2025_4
>>> > > >
>>> > > > You are encouraged to discuss all Draft Policies on PPML. The AC
>>> will
>>> > > > evaluate the discussion to assess the conformance of this draft
>>> policy
>>> > > > with ARIN's Principles of Internet number resource policy as
>>> stated in the
>>> > > > Policy Development Process (PDP). Specifically, these principles
>>> are:
>>> > > >
>>> > > > * Enabling Fair and Impartial Number Resource Administration
>>> > > > * Technically Sound
>>> > > > * Supported by the Community
>>> > > >
>>> > > > The PDP can be found at:
>>> > > >
>>> > > > https://www.arin.net/participate/policy/pdp/
>>> > > >
>>> > > > Draft Policies and Proposals under discussion can be found at:
>>> > > >
>>> > > > https://www.arin.net/participate/policy/drafts/
>>> > > >
>>> > > > Regards,
>>> > > >
>>> > > > Eddie Diego
>>> > > > Policy Analyst
>>> > > > American Registry for Internet Numbers (ARIN)
>>> > > >
>>> > > >
>>> > > >
>>> > > > Draft Policy ARIN-2025-4: Resource Issuance to Natural Persons
>>> > > >
>>> > > > Problem Statement:
>>> > > >
>>> > > > ARIN policies currently restrict the issuance of number resources
>>> to
>>> > > > organizations. This limits access for individuals who are running
>>> networks
>>> > > > under their own legal name, especially in regions where forming or
>>> > > > registering a business is not required or feasible. Other RIRs
>>> such as
>>> > > > RIPE NCC allow individuals to receive resources directly. ARIN
>>> should
>>> > > > consider similar flexibility to ensure equal and consistent access
>>> to
>>> > > > Internet number resources for all operators, regardless of legal
>>> > > > structure.
>>> > > >
>>> > > > Policy Statement:
>>> > > >
>>> > > > This proposal introduces explicit policy text into the NRPM to
>>> allow
>>> > > > number resource issuance to natural persons (individuals) who
>>> provide
>>> > > > valid justification and identity verification.
>>> > > >
>>> > > > Amend NRPM Section 2 to add the following definition:
>>> > > >
>>> > > > 2.18 Organization
>>> > > >
>>> > > > An organization is a company, corporation, partnership, sole
>>> > > > proprietorship, government agency, non-profit entity, educational
>>> > > > institution, or a natural person acting in a capacity consistent
>>> with
>>> > > > operating a network and who meets ARIN’s resource eligibility
>>> criteria.
>>> > > >
>>> > > > Comments:
>>> > > >
>>> > > > Sections 4.2, 5.1, and 6.5 shall be interpreted to allow
>>> “organizations”
>>> > > > as newly defined in Section 2.12, thereby including individuals
>>> where
>>> > > > appropriate.
>>> > > >
>>> > > > Staff may develop identity verification and residency requirements
>>> > > > appropriate to individuals (e.g., government-issued photo ID and
>>> proof of
>>> > > > address).
>>> > > >
>>> > > > All resource justification, utilization, and RSA signing
>>> requirements
>>> > > > remain unchanged.
>>> > > >
>>> > > > There has been extensive discussion of this topic on the ARIN
>>> Public
>>> > > > Policy Mailing List (PPML) in April 2025. Participants have cited
>>> > > > inconsistencies and barriers created by reliance on state-level
>>> business
>>> > > > registries, and called for more inclusive eligibility mechanisms
>>> similar
>>> > > > to other RIR regions. The proposal addresses these concerns while
>>> > > > maintaining accountability and justification requirements.
>>> > > >
>>> > > > Timetable for implementation:
>>> > > >
>>> > > > Recommend implementation within 3–6 months of ratification to
>>> allow ARIN
>>> > > > staff and legal counsel to develop supporting processes.
>>> > > >
>>> > > > Anything else:
>>> > > >
>>> > > > This proposal does not reduce the level of justification required
>>> to
>>> > > > obtain resources, but merely expands eligibility to natural
>>> persons who
>>> > > > operate networks and meet all existing technical and usage
>>> criteria.
>>> > > >
>>> > > >
>>> > > >
>>> > > >
>>> > > >
>>> > > > _______________________________________________
>>> > > > ARIN-PPML
>>> > > > You are receiving this message because you are subscribed to
>>> > > > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>>> > > > Unsubscribe or manage your mailing list subscription at:
>>> > > > https://lists.arin.net/mailman/listinfo/arin-ppml
>>> > > > Please contact info at arin.net if you experience any issues.
>>> > >
>>> > >
>>> > > --
>>> > > ===============================================
>>> > > David Farmer Email:farmer at umn.edu
>>> > > Networking & Telecommunication Services
>>> > > Office of Information Technology
>>> > > University of Minnesota
>>> > > 2218 University Ave SE
>>> <https://www.google.com/maps/search/2218+University+Ave+SE?entry=gmail&source=g>
>>> Phone: 612-626-0815
>>> > > Minneapolis, MN 55414-3029 Cell: 612-812-9952
>>> > > ===============================================
>>> > >
>>> > > _______________________________________________
>>> > > ARIN-PPML
>>> > > You are receiving this message because you are subscribed to
>>> > > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>>> > > Unsubscribe or manage your mailing list subscription at:
>>> > > https://lists.arin.net/mailman/listinfo/arin-ppml
>>> > > Please contact info at arin.net if you experience any issues.
>>> > >
>>> > >
>>> > _______________________________________________
>>> > ARIN-PPML
>>> > You are receiving this message because you are subscribed to
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>>> > Unsubscribe or manage your mailing list subscription at:
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>>> > Please contact info at arin.net if you experience any issues.
>>> _______________________________________________
>>> ARIN-PPML
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>> _______________________________________________
>> ARIN-PPML
>> You are receiving this message because you are subscribed to
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>> Unsubscribe or manage your mailing list subscription at:
>> https://lists.arin.net/mailman/listinfo/arin-ppml
>> Please contact info at arin.net if you experience any issues.
>>
>> _______________________________________________
>> ARIN-PPML
>> You are receiving this message because you are subscribed to
>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>> Unsubscribe or manage your mailing list subscription at:
>> https://lists.arin.net/mailman/listinfo/arin-ppml
>> Please contact info at arin.net if you experience any issues.
>>
>
>
> --
> ===============================================
> David Farmer Email:farmer at umn.edu
> Networking & Telecommunication Services
> Office of Information Technology
> University of Minnesota
> 2218 University Ave SE
> <https://www.google.com/maps/search/2218+University+Ave+SE?entry=gmail&source=g>
> Phone: 612-626-0815
> Minneapolis, MN 55414-3029 Cell: 612-812-9952
> ===============================================
>
> _______________________________________________
> ARIN-PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> Unsubscribe or manage your mailing list subscription at:https://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact info at arin.net if you experience any issues.
>
> --
> John Santos
> Evans Griffiths & Hart, Inc.
>
> _______________________________________________
> ARIN-PPML
> You are receiving this message because you are subscribed to
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>
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