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

[Quantum]

Hi,

I want to express my opposition to this change in the proposal.

The original rationale of Draft Policy ARIN-2025-3, as many people in 
the community seems to have understood it, was to make it easier for 
smaller businesses without at least a /22's worth of IP space to utilize 
ARIN space out of region. However, this change now explicitly forbids 
anyone, even those who demonstratively have a "real and substantial 
connection with the ARIN region", per the current text of NRPM section 
9, from requesting waiting list space for out-of-region use, which is 
currently allowed. If they want to do so, they must now get it from the 
"transfer market" instead.

It is not clear to me why we should be penalizing smaller businesses who 
may not be able to afford IP space from the transfer market, who would 
otherwise have qualified for the waiting list under the current wording 
of NRPM 9, especially not in a policy that purports to /relax/ the 
minimum criteria under section 9 and make it more accessible.

This seems like a massive departure from the original goal of the draft 
policy. In my mind, this feels like a bigger change to ARIN policy than 
the /22 to /24 change. I can't in good conscience support such an 
amendment to a policy titled "Change Section 9 Out Of Region Use Minimum 
Criteria".

If it is the will of the ARIN community to prohibit the use of section 
4.1.8 for out-of-region IP space requests, then it should be done as a 
separate policy with a clear objective, i.e. one titled "Eliminating 
Out-of-Region Use of ARIN Waiting List," and discussed appropriately. It 
should not introduced as an amendment to ARIN-2025-3, originally 
intended for something completely different.

Furthermore, the total prohibition of out-of-region usage justification 
the waiting list now puts global anycast deployments, which necessarily 
involves announcing the same subnet simultaneously inside and outside of 
the ARIN region, in a grey area. By phrasing it this way, it invites 
further questions and may cause ARIN staff to reject any waiting list 
justification that involves anycast, which is permissible under ARIN 
policy today. I don't think this is something we want to do.

Finally, I have concerns regarding the draft language:

On 2026/7/13 10:11, Gerry George via ARIN-PPML wrote:
>
>     Suggested text - Option 1:
>
>
>     */Out of Region usage justification can only be used to acquire
>     IPv4 addresses from the transfer market. Any organization on the
>     Waiting List at the time this policy is implemented will be
>     grandfathered-in./*
>
As you mentioned, this wording will force ARIN to define the concept of 
a "transfer market", which opens a whole can of worms. For example, it 
is not clear to me that mergers & acquisitions under NRPM section 8.2 
would qualify as part of the "transfer market" under the obvious 
definition of market, which opens a whole can of worms if organization A 
acquires organization B and wishes to keep organization B's IP space 
that was used out of region in the same state.

>     Suggested text - Option 2:
>
>
>     */Out of Region usage justification may not be used to receive
>     IPv4 addresses from the ARIN Waitlist (4.1.8), Micro-allocation
>     pool (4.4) or Dedicated IPv4 Allocation to facilitate IPv6
>     Deployment (4.10).  Any organization on the Waiting List at the
>     time this policy is implemented will be grandfathered-in./*
>
As ARIN staff have commented in 
https://www.arin.net/participate/policy/drafts/2025_3/, section 9 does 
not apply to section 4.4 or section 4.10 already, so I am not sure it is 
necessary to mention them here.

Best regards,
Quantum
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