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

[June Slater]

All,

> 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.

Makes sense to me! ARIN's policy of only admitting orgs that have a
business presence in region has historically been quite strict. All other
RIRs except Afrinic have their policy filters at the org level. It's always
seemed odd to me for ARIN to be an outlier here. To that end...

>TO: IPv4: At least a /24 used in region.

I don't see why we should have this restriction at all. If an ARIN-based
entity wants IP space, it shouldn't matter where they seek to use it. That
said, realistically, I don't expect this to pose a problem for most orgs.

>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).

Similar to my comments on ARIN-2025-8, I don't see a reason to be this
protective. ARIN staff has proven to be quite a strict filter on the
special purpose justification space. Adding yet another unnecessary filter
here doesn't seem to simplify, it unnecessarily complicates with limited
benefit.

>From my 2025-8 comment: In August of 2025, roughly 17.8% of 4.10 space was
allocated (with only 26 entities having more than a /22 or more of 4.10
space); while that's not nothing, the burn rate doesn't seem particularly
concerning to me. Do we have data to suggest that this will be
substancially more problematic?

>This section does not apply to section 4.4 or 4.10 space, these sections
have their own restrictions.
Is there a carve out in policy specifically blocking 4.4 or 4.10 space from
Section 9 restrictions? There are additional restrictions on the space,
yes, but I don't see anything precluding it from Section 9.

Absent data showing a need and in light of (in my opinion) a disconnect
between what is written and staff interpretation, opposed to the principle.
As-is, opposed as written.

Regards,
June Slater

On Thu, Aug 20, 2026 at 8:37 AM ARIN <info at arin.net> 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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