[arin-ppml] Draft Policy ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria

[Tyler O'Meara]

Do we need the minimums at all? It seems the "real and substantial connection"
requirement in Section 9 should suffice to prohibit meaningless shell
corporations.

Tyler

On Tue, 2025-03-25 at 13:29 -0700, Scott Leibrand wrote:
> Thanks for including the history of the original policy. I agree that this
> restriction is a bit of an anachronism from the free pool days and could
> safely be relaxed. 
> 
> Scott
> 
> > On Mar 25, 2025, at 9:17 AM, ARIN <info at arin.net> wrote:
> > 
> > On 20 March 2025, the ARIN Advisory Council (AC) accepted “ARIN-prop-341:
> > Change Section 9 Out Of Region Use Minimum Criteria” as Draft Policy.
> > 
> > Draft Policy ARIN-2025-3 is below and can be found at:
> > 
> > https://www.arin.net/participate/policy/drafts/2025_3
> > 
> > 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-2025-3: Change Section 9 Out Of Region Use Minimum
> > Criteria
> > 
> > Problem Statement:
> > 
> > Section 9 of the NRPM, Out of Region Use, requires organizations to use at
> > least a /22 in the ARIN region before they can justify out of region use. 
> > This harms smaller organizations that have less than a /22 in region but do
> > require some out of region use.
> > 
> > Policy statement:
> > 
> > Modify the following text in Section 9:
> > 
> > FROM:
> > 
> > IPv4: At least a /22 used in region.
> > 
> > TO:
> > 
> > IPv4: At least a /24 used in region.
> > 
> > RESULT:
> > 
> > Out of region use of ARIN registered resources are valid justification for
> > additional number resources, provided that the applicant has a real and
> > substantial connection with the ARIN region which applicant must prove (as
> > described below) and is using the same type of resources (with a delegation
> > lineage back to an ARIN allocation or assignment) within the ARIN service
> > region as follows:
> > 
> > IPv4: At least a /24 used in region
> > IPv6: At least a /44 used in region
> > ASN: At least one ASN present on one or more peering sessions and/or routers
> > within the region
> > 
> > Comments:
> > 
> > In my experience when a company needs address space outside of the ARIN
> > region without at least a /22 in region, they go to RIPE and acquire either
> > PI or Legacy space (the least expensive option), often acquiring the space
> > from ARIN sources.
> > 
> > In the case of an inter-regional ARIN to RIPE transfer, RIPE does require
> > the recipient to demonstrate need, as required by ARIN.  ARIN is losing
> > registration of the block and annual fees, as well as the recipient transfer
> > fee.  Most of these recipients would much rather keep everything together in
> > one ARIN account instead of having to go to another registry.
> > 
> > Looking back over the history of Section 9, it was first proposed by Terri
> > Stumme in PROP 189 in May 2013,  and was abandoned.
> > 
> > The Second proposal was by David Farmer in PROP 192 in January 2014 and was
> > abandoned.
> > 
> > The third proposal was by Christian Tacit in PROP 219 in May 2015.  It
> > became draft policy ARIN-2015-5, implemented July 2016. The AC Shepherds
> > were Tina Morris and David Huberman.
> > 
> > In looking over the discussions of the proposals, there was a concern before
> > ARIN ran out of addresses in 2015 that foreign entities would set up shell
> > companies in the ARIN region, looking for free addresses.  Since ARIN is out
> > of address space, that fear is no longer valid.  If there is a fear of
> > swindling the already crowded waiting list, it might be prudent to ban out
> > of region needs demonstration from the waiting list.
> > 
> > Timetable for implementation: 3 months
> > 
> > 
> > 
> > 
> > _______________________________________________
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