[arin-ppml] Request for Comment & Feedback: Draft Policy ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria
Eddie Stauble
eddie at sum.net
Wed Mar 18 13:48:53 EDT 2026
Hi Gerry,
Thanks to you and Doug Camin for shepherding the proposal.
The use of “most” is based solely on my experience; an average of 2-3 per year. I would say 80% of those would rather just stick with ARIN.
I do find it strange that you must have a /22 in region to be able to use section 9, but that there is no upper limit. If you can demonstrate that you need a /16 or larger out of region, you can be approved for it. I personally do not like limiting it to equal or less than current in-region use; several of those buyers needed blocks in multiple out of region locations but only had a /23 or /24 in ARIN.
The very fact that they have a /24 in ARIN means they have not only a connection with the ARIN region, but a real and substantial presence here. So far they have all been US companies with locations in other areas.
From: Gerry E.. George <ggeorge at digisolv.com>
Sent: Wednesday, March 18, 2026 1:10 PM
To: Eddie Stauble <eddie at sum.net>
Cc: 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
Eddie,
Thank you for the detailed explanation and background on the factors that led to the initiation of this process and proposal.
It also provides helpful clarification and some insight regarding Matthew’s point:
"Most of these recipients would much rather keep everything together in one ARIN account instead of having to go to another registry."
Is the use of ‘most’ based on survey data or something else? To me, it seems important to determine whether or not there is a real quantified need.
And also the point raised by Eric is worthy of further discussion:
Should we rewrite the policy to allow any amount of out-of-region use so
long as it is less than or equal to in-region use? (Obviously the usual
needs-based rules also apply).
Using more addresses/prefixes in-region than out-of-region seems like
sufficient evidence of "real and substantial connection with the ARIN
region" and is far better than arbitrary length-based rules.
Let's keep the discussion going.
Gerry E. George
ICT Consultant and Business Solutions Architect;
DigiSolv, Inc. [P.O. Box 1677, Castries, Saint Lucia]
_____
Mobile: (758) 728-4858 / Int'l Office: (347) 450-3444 / Skype: DigiSolv
Email: ggeorge at digisolv.com <mailto:ggeorge at digisolv.com> / LinkedIn: https://www.linkedin.com/in/gerrygeorge/
Please consider the environment before printing this email. Thank you.
_____
From: "Eddie Stauble via ARIN-PPML" <arin-ppml at arin.net <mailto:arin-ppml at arin.net> >
To: arin-ppml at arin.net <mailto:arin-ppml at arin.net>
Sent: Wednesday, March 18, 2026 12:12:19 PM
Subject: Re: [arin-ppml] Request for Comment & Feedback: Draft Policy ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria
Sorry; I posted with the digest subject- first time poster!
-----Original Message-----
From: Eddie Stauble <eddie at sum.net <mailto:eddie at sum.net> >
Sent: Wednesday, March 18, 2026 11:31 AM
To: arin-ppml at arin.net <mailto:arin-ppml at arin.net>
Subject: RE: ARIN-PPML Digest, Vol 249, Issue 16
I am the individual who made this proposal last year. I am an IPv4 broker
and run into this issue on average 2-3 times a year.
The reason I proposed this change is that I see the rule as discriminatory
against the little guy; an injustice that I thought should be easy enough to
remedy.
The typical case is a buyer who has an ARIN account with at least a /24 but
less than a /22. He needs addresses out of region. He cannot justify to
ARIN since he does not have a /22 in region, so he has to go elsewhere.
He would prefer to keep everything in ARIN, and does not want to sign up
with RIPE or APNIC, though sometimes he does. His best option, and what I
typically advise him to do, is to get a legacy block, usually from ARIN,
though sometimes from APNIC, and register it in RIPE, which will incur no
extra fees or dues. The irony is that RIPE requires him to demonstrate need
when a block comes from ARIN.
It does not matter to me personally whether the proposal is accepted; I sell
an IPv4 block either way. I could also make the argument that I stand to
gain more by selling an ARIN legacy block to a buyer registering it as
legacy in RIPE as it is more complicated and takes more time.
Before making this proposal, I wanted to research why a /22 was settled on,
but could not find anything definitive.
>From my research, it looks like out of region needs demonstration was first
proposed by Terri Stumme in PROP 189 in May 2013, and was abandoned.
The Second attempt was by David Farmer in PROP 192 in January 2014 and was
abandoned.
The third attempt was proposed by Christian Tacit in PROP 219 in May 2015.
It became draft policy ARIN-2015-5, implemented July 2016. The AC Shepherds
were Tina Morris and David Huberman.
In looking back over the discussions of the proposals, there was a concern
before ARIN ran out of addresses in September of 2015, that foreign entities
would set up shell companies in the ARIN region, looking for free addresses.
Now that ARIN is out, that fear is no longer valid.
There was a fear of the additional expenses and complexity involved in
verifying out of region use. Since the policy has been in effect for almost
10 years, ARIN should be able to weigh in with an opinion. It would be
interesting to know whether ARIN ever denies out of region needs
demonstration due to the lack of a /22 in region.
There were also concerns expressed about unlimited openness to out of region
use. Strangely, there is a lower limit on in-region use, but there is no
upper limit to how much space can be used out of region, as long as you have
a /22 in region. Has this been a problem?
At the time I made the proposal I was not aware that one could use out of
region use as needs demonstration to get a block from the waiting list. I
do think that language should be added to prevent that, though probably
complicating the issue.
-----Original Message-----
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Subject: ARIN-PPML Digest, Vol 249, Issue 16
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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 (Matthew Cowen)
----------------------------------------------------------------------
Message: 1
Date: Wed, 18 Mar 2026 14:49:09 +0000
From: Matthew Cowen <matthew at dgtlfutures.com <mailto:matthew at dgtlfutures.com> >
To: ARIN PPML <arin-ppml at arin.net <mailto: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: <AEEC2D5C-FC18-4216-87E2-74994B8B461F at dgtlfutures.com <mailto:AEEC2D5C-FC18-4216-87E2-74994B8B461F at dgtlfutures.com> >
Content-Type: text/plain; charset="utf-8"
Mike, thank you for your response. I definately understand there are real
costs involved, especially for small businesses, and potential losses to
ARIN, so thanks for your example. However, my question still stands: is this
a perceived problem or a real one that is quantified and supported by data
in the ARIN community based on the statement that ?most of these
recipients?? and actual use OOR? Doing policy for policy's sake seems like a
waste of time. I have no stake either way, i just think its important to
clarify that statement.
Apologies, if I implied anything nefarious from the operators. That wasn?t
my intention. I mentioned my local case as an illustration.
On 18 Mar 2026, at 10:20, Mike Burns <mike at sum.net <mailto:mike at sum.net> > wrote:
Hi Matthew,
That?s a reasonable question.
Considering the sizes at issue here, the costs of creating and maintaining
an account at a foreign registry can be a high fraction of the IPv4 purchase
cost, and so it would be unusual for any small ARIN account holder to prefer
the costs and burdens of multiple registry accounts.
The example examined the case of a small ARIN company requiring a /24 for
overseas use, and being forced to register that /24 at RIPE, whose initial
membership fee and ongoing fees for a /24 can quickly double the cost of
that /24 to that small ARIN company, to say nothing of the administrative
burdens or the loss of revenue to ARIN. This is an actual real example and
we were forced by the policy to address the user?s need in this expensive
manner. This policy would have avoided that.
It is actually not unusual for larger companies to have RIR accounts at
multiple registries and there is nothing nefarious about it.
Regards,
Mike
From: ARIN-PPML
<arin-ppml-bounces at arin.net <mailto:arin-ppml-bounces at arin.net%3cmailto:arin-ppml-bounces at arin.net> <mailto:arin-ppml-bounces at arin.net>> On Behalf Of
Matthew Cowen via ARIN-PPML
Sent: Wednesday, March 18, 2026 8:17 AM
To: ARIN PPML <arin-ppml at arin.net <mailto:arin-ppml at arin.net%3cmailto:arin-ppml at arin.net> <mailto: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
Quick question. The ?At issue? statement says:
"Most of these recipients would much rather keep everything together in one
ARIN account instead of having to go to another registry."
Is the use of ?most? based on survey data or something else? To me, it seems
important to determine whether or not there is a real quantified need.
I?d support the overall idea of the policy (although not as currently
proposed), but I think it should be unambiguous with respect to who and how
many are demanding this, and also potential for abuse, as highlighted. There
is a local case with Orange Cara?bes, the caribbean entity of Orange France,
with a mish-mash of resources from ARIN/RIPE! Possibly other FWI/France
operators too.
On 17 Mar 2026, at 04:54, Gerry E.. George
<ggeorge at digisolv.com <mailto:ggeorge at digisolv.com%3cmailto:ggeorge at digisolv.com> <mailto:ggeorge at digisolv.com>> wrote:
Hello & Good day to PPML Community.
As assigned shepherds, Matthew Wilder & myself are seeking feedback &
comments on the current version of the Draft Policy ARIN-2025-3: Change
Section 9 Out Of Region Use Minimum Criteria.
I have summarized the key points below, but the full policy can be accessed
here:
https://www.arin.net/participate/policy/drafts/2025_3/
ARIN-prop-341 (ARIN-2025-3) - Change Section 9 Out Of Region Use Minimum
Criteria
In brief:
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.
Proposal:
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.
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
* 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
At issue:
When a company needs address space outside of the ARIN region without at
least a /22 in region, they go to RIPE and acquire either PI or Legacy space
(the least expensive option), often acquiring the space from ARIN sources.
In the case of an inter-regional ARIN to RIPE transfer, RIPE does require
the recipient to demonstrate need, as required by ARIN. ARIN is losing
registration of the block and annual fees, as well as the recipient transfer
fee. Most of these recipients would much rather keep everything together in
one ARIN account instead of having to go to another registry.
While there are no material legal issues, it is anticipated that this change
in policy would significantly increase the volume of IPv4 waitlist requests
and could lead to an increase to staff ticket workload.
Because the policy requirements for an organization to justify an initial
/24 are generally straightforward to meet, it is expected that more
organizations may request a /24 primarily to qualify for additional
ARIN-issued IPv4 addresses for out-of-region use. It is expected that this
would result in more ARIN IPv4 space being used out of region.
Concern regarding possible abuse of the reduced requirement in order to
obtain ARIN resources, particularly for blocks larger than the minimum (/24)
for OOR use.
Considerations:
- How much of an issue could this be? Does it matter to the community?
- Should there be a requirement for the OOR use be not more/greater than the
in-ARIN region use?
- Can this unfavorably impact companies having more growth OOR, and drive
them to other RIRs and away from ARIN in such instances?
- Is there a probability for potential abuse via the Waitlist, and if so,
should there be consideration for limitations to the designated region use
for 4.1.8. requests?
- Is the "real and substantial connection" requirement in Section 9 be
sufficient to prohibit or reduce the potential for abuse?
Questions:
Are you in support of the policy?
Are there any additional issues which should be considered?
Should the AC continue working on the policy as written?
And remember, the ARIN public policy process runs on positive consensus not
silent assent, so please weigh in. We look forward to your engagement.
Thanks.
Gerry E. George
ICT Consultant and Business Solutions Architect; DigiSolv, Inc. [P.O. Box
1677, Castries, Saint Lucia] ________________________________
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My best/Cordialement,
Matthew Cowen
?
My best/Cordialement,
Matthew Cowen
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