[arin-ppml] ARIN-PPML Digest, Vol 254, Issue 4
Eddie Stauble
eddie at sum.net
Mon Aug 10 10:00:30 EDT 2026
Small companies use the waiting list all the time. They also use transfers
when they cannot wait.
You are correct; the policy as originally proposed in Prop 341 was solely to
help those who did not have a /22 in region.
In the discussion of that policy at ARIN meetings, the waiting list came up.
I have to admit that I did not realize out of region justification could be
used to get addresses from the waiting list.
To my knowledge, the waiting list started when the ARIN free pool was
exhausted in September 2015. The out of region usage policy was
implemented in July 2026.
I saw no discussion of the waiting list in the original discussions of out
of region need. Either I missed it, or the community did not realize that
out of region use was acceptable for the waiting list, or it was just
assumed?
So due to the objections to the potential/real? abuse of the waiting list,
the proposal has morphed into "kill two birds with one stone"; let virtually
anyone use out of region justification, and preclude all out of region
justification from the waiting list.
So the question to the community is:
Should those with less than a /22 currently registered with ARIN be allowed
to use out of region need for justification to ARIN for future IPv4
acquisitions?
and
Should anyone using out of region need demonstration be able to get
addresses from the waiting list, or only those with in region needs
demonstration?
Regards,
Eddie
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Today's Topics:
1. Re: ARIN-PPML Digest, Vol 254, Issue 2 (egh.johns at gmail.com)
2. Re: ARIN-PPML Digest, Vol 254, Issue 3 (Eddie Stauble)
3. Re: ARIN-PPML Digest, Vol 254, Issue 3 (Quantum)
----------------------------------------------------------------------
Message: 1
Date: Thu, 6 Aug 2026 13:23:30 -0400
From: egh.johns at gmail.com
To: arin-ppml at arin.net
Subject: Re: [arin-ppml] ARIN-PPML Digest, Vol 254, Issue 2
Message-ID: <7bcffa66-c684-4f41-95e2-ba3f2017f111 at gmail.com>
Content-Type: text/plain; charset=UTF-8; format=flowed
I think there is a fundamental misunderstanding here.? The intent of the
policy proposals (and, IIUC, the implementation by ARIN of the exiting
policies) is NOT to restrict geographically the usage of ARIN-provided IP
addresses.? If you have ARIN-supplied IP addresses, you can use them where
ever you want (within the restrictions of whatever pool they came from.*)
These policies pertain to justification for acquiring additional address
space, over and above the space they already have.? The general, overarching
principle is that users should acquire resources from whichever Internet
Registry is responsible for the geographic area of the user's preponderance
of use.
There is no need for ARIN to manage a database of where each and every block
and address is used (blocks can and are subnetted so addresses in them can
be used in more than one region.)? It is the responsibility of the holder,
if and only when they are applying for additional space, to document their
current usage and prove that they NEED additional space, and the user can't
count too much out-of-region use to demonstrate that need.? If they are
using most of their existing allocations, but too much of it is
out-of-region, they should be acquiring additional allocations from the
registry responsible for what ever region they need the resources in, not
from ARIN.
These policy debates pertain to fiddling with the edge cases and
justification requirements for acquiring additional resources, not for use
of resources the user currently holds.
Excuse me, steward!? Could you please move my deck chair closer to the
stern??
That seems to be sinking more slowly.
[*] In addition to the general use pools, supplied from the waiting list,
M&A, the IPv4 address market, etc., there are some special restricted pools,
such as the pool for Essential Infrastructure and the pool for IP4 -> IP6
migration and co-existence.? The restrictions on these pools pertain almost
entirely to usage, not geography.)
On 8/4/2026 1:25 AM, Quantum via ARIN-PPML wrote:
> Hi Eddie,
>
> On 2026/8/3 23:09, Eddie Stauble via ARIN-PPML wrote:
>> As an IPv4 broker, I run into several cases per year where a small
>> company is based in the US but has a branch office elsewhere in the
>> world. They have a /24 for BGP here in the US, and want to do the
>> same in the UK. Under existing policy, they cannot use their need in
>> the UK for justification since they have less than a /22 in region. So
they end up going to RIPE.
>> They would rather just keep it all in ARIN. This proposal would
>> allow them to do that.
>
> What I am struggling to understand is why this is a problem only for
> users of
> IPv4 brokers and not users of the IPv4 waiting list. If the same small
> company wanted to use the ARIN waiting list instead of purchasing IPv4
> space from you, they would run into the exact same problem.
>
>> The waiting list should be used for those who have a need in the ARIN
>> region.
>
> It is not clear to me why this should be the case. In my opinion, if
> using space out-of-region is something that ARIN permits, then it
> should be permitted for all ARIN members. I don't believe ARIN
> membership should be divided into two separate classes: those who use
> IPv4 brokers, and those who use the waiting list, with the former
> allowed to get space for out-of-region uses and the latter prohibited
> from doing so.?I don't believe this is good for the health of the ARIN
community.
>
> Furthermore, if ARIN waiting list space is to be reserved for
> in-region use exclusively, then section 8.3 transfers becomes a
> loophole. One could obtain space under the ARIN waiting list, wait 60
> months for the prohibition against transfer under section 4.1.8 to
> expire, and then transfer the space under section 8.3 to another ARIN
> member, who is suddenly allowed to use it out-of-region. I don't think
this creates the right incentives.
>
> Under the current proposal, ARIN would also be forced to track whether
> a specific block is permitted to be used out-of-region and which ones
> aren't, based on how the member received the space. If we wish to plug
> the aforementioned section 8.3 loophole by allowing the out-of-region
> ban to carry over after a transfer, ARIN would be forced to do even
> more bookkeeping. A question for ARIN staff is whether this is
> something they can reasonably do, and whether it makes sense for ARIN to
police this.
>
> In my opinion,?draft policy ARIN-2025-3 should either permit
> out-of-region use with a single IPv4 /24 in region for everyone, or be
> abandoned outright. If the concern is the waiting list being abused,
> then I suggest we institute some other requirement that applies
> equally to all members, regardless of whether they get space from section
4.1.8 or section 8.
>
> Best regards,
> Quantum
>
>
> _______________________________________________
> ARIN-PPML
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John Santos
Evans Griffiths & Hart, Inc.
------------------------------
Message: 2
Date: Thu, 6 Aug 2026 13:40:41 -0400
From: "Eddie Stauble" <eddie at sum.net>
To: <arin-ppml at arin.net>
Subject: Re: [arin-ppml] ARIN-PPML Digest, Vol 254, Issue 3
Message-ID: <047b01dd25ca$b3ab6a80$1b023f80$@sum.net>
Content-Type: text/plain; charset="us-ascii"
Hi Quantum,
Disallowing out of region justification for those with less than a /22 in
region is an issue for anyone with less than a /22, whether they are looking
to get addresses from a broker or private transfer. Not all 8.3 transfers
are through brokers. The original part of this proposal was strictly about
who can use their out of region need for justification, not about how they
were going to get the addresses.
I don't have any ulterior motives in proposing this; I sell an IPv4 block
either way. I just see the requirement of a /22 for in region use to be
discriminatory against the little guy.
The waiting list has been a big help to organizations, especially back in
2022 when the wait was a maximum of 90 days and prices on the transfer
market were high and sellers scarce. The wait time did balloon up to 2
years; it looks like it is down to about 9 months now. So in the case of
organizations needing addresses now, the waiting list is not an option now,
nor has been in the past, except for a brief period of a year or so after
the Micfo pause.
There has also been abuse of the waiting list, however it was justified. We
have run into sellers of waiting list addresses, some quite soon after
getting them. If I'm not mistaken ARIN is aware of waiting list addresses
showing up on leasing platforms soon after being distributed.
In discussions of this original proposal the subject of the waiting list
came up, and others like myself were a bit surprised that out of region
usage could be used to justify space from the waiting list. Many of us were
of the opinion that the waiting list should be reserved for those who need
space in region. After all, it is the ARIN waiting list. Hence the
addition of it to this proposal. It certainly won't stop waiting list
abuse, but it should cut it down.
I think the 8.3 loophole is a bit far-fetched; to my knowledge ARIN does not
police how a recipient routes a block, except perhaps if/when the recipient
requests more space. So that waiting list recipient can route the block
however they want with no penalty. If the recipient transfers the block 5
years or more after receiving it, and the recipient of that transfer uses it
out of region, whether justified in or out, I don't see that as a major
issue and doubt that ARIN would either.
I do agree that these would probably be better as two separate proposals,
but they are related, and with the time and energy it takes to make and
promote a proposal, linking them is just easier.
Regards,
Eddie
-----Original Message-----
From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of
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Sent: Tuesday, August 4, 2026 12:00 PM
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Subject: ARIN-PPML Digest, Vol 254, Issue 3
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Today's Topics:
1. Re: ARIN-PPML Digest, Vol 254, Issue 2 (Eddie Stauble)
2. Re: ARIN-PPML Digest, Vol 254, Issue 2 (Quantum)
----------------------------------------------------------------------
Message: 1
Date: Mon, 3 Aug 2026 23:09:39 -0400
From: "Eddie Stauble" <eddie at sum.net>
To: <arin-ppml at arin.net>
Subject: Re: [arin-ppml] ARIN-PPML Digest, Vol 254, Issue 2
Message-ID: <01cc01dd23be$affee960$0ffcbc20$@sum.net>
Content-Type: text/plain; charset="us-ascii"
Thanks Chris and hi Quantum,
Thank you for your thoughts regarding this proposal. As the original author
of this policy, I wanted to chime in.
As an IPv4 broker, I run into several cases per year where a small company
is based in the US but has a branch office elsewhere in the world. They
have a /24 for BGP here in the US, and want to do the same in the UK. Under
existing policy, they cannot use their need in the UK for justification
since they have less than a /22 in region. So they end up going to RIPE.
They would rather just keep it all in ARIN. This proposal would allow them
to do that.
The waiting list should be used for those who have a need in the ARIN
region. It would be helpful if ARIN could provide information on how often
out of region needs demonstration is currently used to get address space
from the waiting list.
Prohibiting out of region needs justification from the waiting list might be
better as a separate proposal. Though as I've come to find out, in the real
world these proposals move at a snail's pace, and in that sense I think they
need to be tied together.
Like Chris, I don't see a problem with anycast; if announced at all in ARIN,
it's in region.
Good point about 4.4 and 4.10 space. Based on these and earlier comments, I
do think that the suggested option 1 could be changed to:
Out of Region usage justification may not be used to receive IPv4 addresses
from the ARIN Waitlist (4.1.8). Organizations on the Waiting List at the
time this policy takes effect shall be exempted and will not be affected by
this change.
Regards,
Eddie Stauble
-----Original Message-----
From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of
arin-ppml-request at arin.net
Sent: Monday, August 3, 2026 12:00 PM
To: arin-ppml at arin.net
Subject: ARIN-PPML Digest, Vol 254, Issue 2
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Today's Topics:
1. Re: Request for Comment & Feedback: Draft Policy ARIN-2025-3:
Change Section 9 Out Of Region Use Minimum Criteria (Chris Woodfield)
----------------------------------------------------------------------
Message: 1
Date: Sun, 2 Aug 2026 10:36:14 -0700
From: Chris Woodfield <chris at woodfield.tech>
To: arin-ppml at arin.net
Subject: Re: [arin-ppml] Request for Comment & Feedback: Draft Policy
ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria
Message-ID: <395CE528-C186-4D0C-B163-59E43D9D09E8 at woodfield.tech>
Content-Type: text/plain; charset="us-ascii"
> 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.
>
To comment on this particular point - in my experience, anycast has never
been interpreted as out of region use, as long as at least one site
advertising the routes is within the ARIN region. If the potential for this
to be interpreted differently is a concern for the community, language
making this nuance explicit would be ripe for a new policy proposal.
Regards,
-Chris
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Message: 2
Date: Tue, 4 Aug 2026 01:25:28 -0400
From: Quantum <arin at quantum5.ca>
To: arin-ppml at arin.net
Subject: Re: [arin-ppml] ARIN-PPML Digest, Vol 254, Issue 2
Message-ID: <47353320-2e6a-49ce-8e82-4b3ea0224cff at quantum5.ca>
Content-Type: text/plain; charset="utf-8"; Format="flowed"
Hi Eddie,
On 2026/8/3 23:09, Eddie Stauble via ARIN-PPML wrote:
> As an IPv4 broker, I run into several cases per year where a small
> company is based in the US but has a branch office elsewhere in the
> world. They have a /24 for BGP here in the US, and want to do the
> same in the UK. Under existing policy, they cannot use their need in
> the UK for justification since they have less than a /22 in region. So
they end up going to RIPE.
> They would rather just keep it all in ARIN. This proposal would allow
> them to do that.
What I am struggling to understand is why this is a problem only for users
of IPv4 brokers and not users of the IPv4 waiting list. If the same small
company wanted to use the ARIN waiting list instead of purchasing IPv4 space
from you, they would run into the exact same problem.
> The waiting list should be used for those who have a need in the ARIN
> region.
It is not clear to me why this should be the case. In my opinion, if using
space out-of-region is something that ARIN permits, then it should be
permitted for all ARIN members. I don't believe ARIN membership should be
divided into two separate classes: those who use IPv4 brokers, and those who
use the waiting list, with the former allowed to get space for out-of-region
uses and the latter prohibited from doing so.?I don't believe this is good
for the health of the ARIN community.
Furthermore, if ARIN waiting list space is to be reserved for in-region use
exclusively, then section 8.3 transfers becomes a loophole. One could obtain
space under the ARIN waiting list, wait 60 months for the prohibition
against transfer under section 4.1.8 to expire, and then transfer the space
under section 8.3 to another ARIN member, who is suddenly allowed to use it
out-of-region. I don't think this creates the right incentives.
Under the current proposal, ARIN would also be forced to track whether a
specific block is permitted to be used out-of-region and which ones aren't,
based on how the member received the space. If we wish to plug the
aforementioned section 8.3 loophole by allowing the out-of-region ban to
carry over after a transfer, ARIN would be forced to do even more
bookkeeping. A question for ARIN staff is whether this is something they can
reasonably do, and whether it makes sense for ARIN to police this.
In my opinion,?draft policy ARIN-2025-3 should either permit out-of-region
use with a single IPv4 /24 in region for everyone, or be abandoned outright.
If the concern is the waiting list being abused, then I suggest we institute
some other requirement that applies equally to all members, regardless of
whether they get space from section 4.1.8 or section 8.
Best regards,
Quantum
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Message: 3
Date: Thu, 6 Aug 2026 19:52:42 -0400
From: Quantum <arin at quantum5.ca>
To: arin-ppml at arin.net
Subject: Re: [arin-ppml] ARIN-PPML Digest, Vol 254, Issue 3
Message-ID: <afaf9c05-c71a-4e25-a42c-72022b490e28 at quantum5.ca>
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Hi Eddie,
On 2026/8/6 13:40, Eddie Stauble via ARIN-PPML wrote:
> Disallowing out of region justification for those with less than a /22 in
> region is an issue for anyone with less than a /22, whether they are
looking
> to get addresses from a broker or private transfer. Not all 8.3 transfers
> are through brokers. The original part of this proposal was strictly about
> who can use their out of region need for justification, not about how they
> were going to get the addresses.
My original question was not about the impact of the current NRPM
section 9 on brokers versus private transfers. Rather, it was about that
between /transfers in general/ versus /the waiting list./ Specifically,
I wrote:
> What I am struggling to understand is why this is a problem only for
> users of IPv4 brokers and not users of the *IPv4 waiting list.* If the
> same small company wanted to use the *ARIN waiting list* instead of
> purchasing IPv4 space from you, they would run into the exact same
> problem.
If the proposal was solely about helping those who do not have a /22 in
region, regardless of *how they were going to get the addresses* (your
words), why are we now restricting the remedy to only those who use
brokers and private transfers, and denying the remedy to those who use
the waiting list? After all, any user of the ARIN waiting list will
experience the exact same problem.
Why does one group deserve the remedy and the other doesn't? I think
this fundamentally grants one group of ARIN members more privilege than
the other. I firmly believe that all ARIN members should be allowed to
do the same thing with their space. The waiting list is not a special
pool those reserved for NRPM sections 4.4 and 4.10 and shouldn't have
special restrictions.
In fact, this latest amendment goes beyond not granting the remedy to
users of the waiting list: it deprives the users of the waiting list of
a justification they were previously able to use, when they have more
than a /22 in region. So really, this is harming one group of ARIN
members to benefit another group.
> I don't have any ulterior motives in proposing this; I sell an IPv4 block
> either way.
I've never suggested that you had any ulterior motives. I merely wanted
to remind you that users of the waiting list experience the same issue.
Your original proposal would help many ARIN members and I am not opposed
to it.
> I just see the requirement of a /22 for in region use to be
> discriminatory against the little guy.
And I see the new amendment as discriminatory against those
organizations who use the waiting list instead of the "transfer market",
i.e. IP brokers or private transfers. The amendment forces any ARIN
member with a /22 in region who would have qualified to use the waiting
list for space out of region to either:
1. use a different RIR; or
2. buy IP space on the transfer market instead, which costs a lot more
than the waiting list that they are currently able to use.
If we cared about the little guy, why are we doing this to them?
Remember, anyone who uses the ARIN waiting list /is/ the little guy in
the grand scheme of things. To quote NRPM section 4.1.8:
> Organizations which hold more than a /20 equivalent of IPv4 space in
> aggregate (exclusive of special use space received under section 4.4
> or 4.10) are not eligible to apply.
I oppose this amendment to the proposal, and if this amendment is to be
bundled with the original proposal, then I have no choice but to oppose
the whole thing.
Best regards,
Quantum
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