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

[Peter Potvin]

Hello,

Please see my comments below:

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.

This draft policy aims to reduce the harm to organizations that wish to use
address space outside of the ARIN region, without currently having a /22
used within the region. This is understandable and I agree that this is a
problem needing to be addressed, as not every organization may have the
capability to use a full /22 within the region before expanding their
network outside of it.

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.

I can accept the above-quoted text from the proposal as written, as it
aligns with and resolves the problem statement of harming those with less
than a /22 used within the region and requiring out-of-region use.

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).

I cannot agree with the above because it fails to align with the problem
statement provided for the initial proposal, and as such may actually do
more harm than good. This specific modification as written would restrict
ARIN members to obtaining resources for out-of-region use only through a
Section 8 transfer. As such, this modification has no relation to the
initial problem statement and should be made as part of its own proposal
under the specific NRPM sections to which it applies, if ARIN wishes to
proceed with the change.

For these reasons, this draft reaches beyond the problem statement by not
only addressing the problem being raised but also by adding further
restrictions that are out-of-scope of the draft policy's clear goals.

I strongly oppose this version of the draft policy.

Kind Regards,
Peter Potvin

On 2026-08-20 11:37 a.m., ARIN wrote:

The following Draft Policy has been revised:

*Draft Policy ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria

Revised text 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.

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.

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

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.

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






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