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

[Tyler Donia]

Good evening,

I would also like to express my strong opposition to the revised version 
of ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria as 
written.

The original version of this proposal, along with its title and stated 
purpose, was to reduce the burden on smaller ARIN members for 
out-of-region justification of new address space by reducing the 
out-of-region justification requirement from a /22 to a /24. This 
change, I support, as I believe that requiring small organizations to 
acquire a /22 of address space through some means before they may 
request out-of-region space is impractical.



Unfortunately, the amended version of the proposal wildly expands its 
scope and transforms it into a policy proposal I cannot support. The 
revised version of this 'change out of region eligibility criteria' 
proposal adds large additional constraints to other unrelated components 
of the NRPM and number request process. More specifically, per my 
reading, it removes out-of-region use entirely as justification for 
*ANY* IPv4 resources requested directly from ARIN and leaves open only 
the 'transfer market'.



I feel that this amendment to the proposal is difficult to reconcile 
with the PDP principle of enabling fair and impartial number resource 
administration, under which the Advisory Council must evaluate this 
draft. Although many state that the 'transfer market' is a valid and 
feasible way to obtain addresses, I believe some are failing to consider 
that the 'transfer market' is not a practical option for the types of 
organizations that this proposal purports to support. This is true for a 
number of reasons, primarily that IPv4 addresses are expensive. For many 
small businesses, being told to find $10k or more to spend on the 
transfer market is not a practical answer, and this amendment would 
leave them no alternative by closing the standard allocation path entirely.



To use the waitlist as an example, I do not think ARIN should make it 
its policy to categorically exclude a group of operators like myself 
(who are willing to work through the waitlist allocation process and 
wait for a block to be available) from internet resources that they have 
demonstrated a need for, nor should ARIN be essentially forcing this 
group to pay exorbitant prices on the private market. The waitlist is 
also in effect exclusively used by 'small networks' due to its size 
restrictions and long wait times. I suspect that many of those on the 
list with out-of-region use cases would be unreasonably harmed by this 
change, whereas larger businesses or larger networks that may or may not 
be eligible for the waitlist in the first place would have no issue 
ponying up $10k for an out-of-region-approved block. I do not see how 
excluding a specific subset of entities operating within ARIN's service 
region from direct registry service can be described as fair and 
impartial administration.

This proposal also makes the unprecedented change of restricting 
waitlist eligibility on the basis of the *intended use* of the addresses 
requested. Historically, every codified restriction on waitlist requests 
has been based on who the applicant is or what resources they already 
hold. None have been based on the purpose of the requested addresses, or 
how that organization may choose to utilize them within their 
infrastructure. My interpretation of the waitlist's purpose is that it 
serves as a catch-all: if you do not qualify for one of the 
special-purpose pools, you may still document your need and wait. This 
proposal would create the first category of need that ARIN policy 
expressly designates as valid justification under Section 9, but for 
which ARIN will issue no addresses under any circumstances.



I understand that out-of-region use is at best a secondary priority for 
ARIN. However, Section 9 already requires a real and substantial 
connection to the ARIN service region, so the organizations affected 
here are ARIN's own constituents, not entities shopping for a registry. 
Directing them to another RIR is not a costless redirection: obtaining a 
single /24 from the RIPE NCC, for example, currently requires 
establishing and indefinitely funding an LIR account at roughly EUR 
1,800 per year plus a sign-up fee, for a multi-year wait and a one-time 
allocation, for a need they can *already* document to their current RIR 
(ARIN).

This policy would also, in effect, create a distinction in the service 
offered by ARIN based purely on the amount of resources (money) the ARIN 
member is willing to expend. By completely closing direct IPv4 
allocations for out-of-region use, those ARIN members who have 
completely legitimate reasons to request space from ARIN for use outside 
the ARIN service region would only receive registry services from ARIN 
if they were willing to expend large amounts of money with an unrelated 
third party. This seems like a strange and concerning system to 
introduce in a proposal intended to help smaller networks.



The amended proposal would also result in the policy directly 
contradicting itself, at least to a reader without a legal background 
such as myself (emphasis and cuts mine):

On 8/20/26 11:37 AM, ARIN wrote:
>
> 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:
>
> [...]
>
> ***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).***
>

Although I understand that ARIN policy additionally requires 
justification for transferred-in resources, I find the amended policy to 
be confusing and contradictory, as it states that out-of-region use is 
justification but then excludes all ways of directly receiving an 
allocation from ARIN for a specific class of resources (IPv4). In my 
eyes, this means that it is in fact not valid justification. If the 
community wishes to proceed with this specific policy (of no longer 
allowing out-of-region direct allocations of IPv4 resources to ARIN 
members), then I would suggest a rewording is in order, as the policy 
provides a 'justified use case' for which ARIN bars direct allocations.



To conclude, as others have mentioned, the amended version of this 
proposal would, in my opinion, be far better as a set of separate, 
narrowly tailored policy proposals, such as the ARIN-2025-8 draft policy 
that already exists, rather than as a 'five birds with one stone' policy 
proposal that claims to help the very people that this amended proposal 
would harm. This amendment essentially creates two tiers of IPv4 
addresses within ARIN policy, which is a much broader and more complex 
change than the original text of this proposal, and presents its own set 
of challenges and concerns that should be discussed separately.

Although I would have supported this proposal as it was originally 
written, I cannot support the amended version due to the harm it would 
directly cause to small business network operators like myself, and I 
must therefore oppose this proposal as it is written.

Warmly,
-T
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-ppml/attachments/20260820/ccaf621e/attachment.htm>