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

[Quantum]

Hello,

I am very concerned at the way this draft policy has been revised and I 
want to reiterate my opposition.

On 2026-08-20 11:37, ARIN wrote:
> 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.
The stated goal of this draft policy is to reduce harm to smaller 
organizations in ARIN who have less than a /22 in region and require 
some out of region use, as noted here.
> 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.

This part of the proposed policy fulfills that goal and I am not opposed 
to it.

> Out-of-Region Usage Justification may not be used to receive IPv4 address space from the ARIN Waiting List (4.1.8), the Micro-allocation Pool (4.4), or the Dedicated IPv4 Block to Facilitate IPv6 Deployment (4.10).
>
> Any organization already on the Waiting List at the time this policy is implemented will be exempted and shall remain eligible under the rules in effect at the time of its placement on the Waiting List.

This part of the draft policy has nothing to do with the stated goal and 
represents a fundamental change to ARIN's allocation policy, not an 
adjustment to the minimum criteria for NRPM section 9 per the title and 
stated goal of the draft policy. This should not be added as an 
amendment to a policy.

We have entire policy proposals like ARIN-2025-8 
<https://www.arin.net/participate/policy/drafts/2025_8/>, which only 
prohibits the out-of-region use of NRPM section 4.10, that changes less 
than this /amendment/ to the draft policy. In fact, if the current draft 
of ARIN-2025-3 passes, it would render ARIN-2025-8 completely pointless 
and all the objections to it moot.

Given the broad scope of this change and how it has /nothing/ to do with 
the stated goal, this provision should be a *separate* policy so that 
the community can properly participate and debate the merits of the 
change. It should *not* be bundled as an *amendment* to a policy draft 
whose name and stated goal has nothing to do with the provision. This 
prevents the ARIN community from properly debating the policy change and 
I cannot in good conscience support this.

Also, the portion that blanketly prohibits out-of-region usage 
justifications for the ARIN Waiting List (section 4.1.8) has massive 
implications. Unlike the reserved pools under section 4.4 and 4.10, 
there are currently no limitations to the potential uses of ARIN 
resources from the waiting list outside of those that apply to all IPv4 
resources under NRPM section 4, only on the amount of space to ensure a 
fair allocation. As such, users of the ARIN waiting list can currently 
benefit from the full suite of services provided by ARIN.

Under this proposal, users of the ARIN waiting list (or any reserved 
pools) will no longer be able to access the out-of-region justification, 
meaning that the /only/ way to acquire new IPv4 resources for 
out-of-region use would be through a section 8 transfer, which in 
practice, means acquiring resources from a /third-party/ that is not the 
ARIN member or ARIN itself. It means that the full suite of ARIN's 
services will no longer be accessible without a third-party willing to 
transfer resources, which in practice requires paying such parties large 
sums of money. I find this change very concerning, as members will no 
longer be able to access the full scope of ARIN's services by dealing 
with ARIN itself.

Furthermore, the stated goal of the policy is to reduce "harm" of 
smaller ARIN organizations who wishes to use resources out of region. 
Recall under NRPM section 4.1.8 that:

> 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.

In effect, this means that all ARIN members who use the waiting list are 
small organizations in the grand scheme of things. By prohibiting the 
ability of such small organizations to use the waiting list, it forces 
them to acquire IPv4 resources from the market, which is a lot more 
costly than the waiting list. In essence, this policy /harms/ small 
organizations that hold between a /22 and /20 of IPv4 space.

This harm is not necessary to accomplish the stated goal of this draft 
policy. There is also, to my knowledge, no known influx of out-of-region 
requests on the waiting list from ARIN organizations holding between a 
/22 and /20 that justifies such an intervention. So why are we 
penalizing this group of ARIN organizations when they have done no 
wrong? For a policy that's supposed to reduce harm, it just harms a 
/different/ group of ARIN members for no good reason.

In conclusion, the current formulation of Draft Policy ARIN-2025-3 
contains provisions that have nothing to do with the stated goal of the 
policy, and these provisions have wide-reaching consequences and inflict 
direct and unnecessary harm on a different group of small ARIN members. 
I firmly oppose this version of the policy.

Best regards,
Quantum
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