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

[Quantum]

Hi Doug (and the other ARIN AC members),

Thanks for answering my questions here and on the Virtual Policy Open House.

On 2026-10-08 09:24, Douglas Camin wrote:
> I'm glad that the exchange helped build a better understanding about 
> this policy. The items you've brought up are definitely part of the 
> feedback and input that the shepherds will be taking into account. The 
> suggested changes below are also helpful; it's great to have concrete 
> language suggestions.
>
> I'll defer to the shepherds and their role in the process but offer 
> the reminder that in a few weeks we have the next public policy 
> meeting (ARIN58) in Miami. The policy will be presented from the stage 
> and live feedback solicited from the community. I encourage you to 
> participate (virtually or in person) if possible.

I'll be sure to participate in the discussions at ARIN 58. However, 
before I do that, I do have some questions that I would like clarified 
regarding the interpretation of this policy based on the discussions 
here and at the Virtual Policy Open House:

Question 1: What is ARIN's understanding of the term "justification" in 
the context of requesting additional resources? The way I understand it 
(and I imagine similarly for most LIRs), "justification" means the 
questions in the "justification" section when requesting IP resources on 
the ARIN portal, which asks what product and services you intend to 
offer and how you are going to be using the new space. In the context of 
NRPM sections 4.4 and 4.10, "justification" is also straightforwardly 
the intended use case of the new space. As such, I interpreted 
ARIN-2025-3 as blocking requests that say, for example, "I want a new 
/24 to use in Frankfurt."

Based on this discussion, it seems that only the requirements of NRPM 
section 4.2.4, such as utilization percentage, are considered 
"justification" in this case. Is that correct? If it is, and such 
"justification" only concerns itself with existing usage, then under 
ARIN-2025-3, provided that you meet the proposed 80% in-region usage 
requirement, you can request a /22 solely for out-of-region use, even if 
it would put you under the 80% in-region use requirement after receiving 
the new space and utilizing it?

Furthermore, if "justification" only concerns existing usage, are you 
able to request additional resources intended to be used outside of the 
ARIN region under the /current/ version of the NRPM, if you currently 
only hold a /24 and uses it in-region? Because if "justification" only 
concerns existing usage, then requesting additional resources intended 
to be used out-of-region when all your current usage is in-region means 
that such a request wouldn't considered an "out-of-region" request, and 
section 9 will not apply at all.

Question 2: Will ARIN-2025-3 put LIRs in a situation where they cannot 
request any resources from ARIN without renumbering their networks 
out-of-region? For example, if an LIR doesn't currently meet the 80% 
in-region requirement, but wishes to request additional space for use 
/within/ the ARIN region, are they prohibited from doing so? If so, it 
appears that it would require said LIR to renumber their networks 
out-of-region meet the 80% in-region requirement before they can request 
/any/ resources, which might be a big lift.

Previously, as long as an LIR is using a /22 in region, they would 
always be able to apply for additional space, so this would be a pretty 
big change, and I am not sure exempting those currently on the waiting 
list is sufficient.

Question 3: Under NRPM section 8.3, it says "the resources transferred 
will be subject to current ARIN policies," and similarly for incoming 
transfers in section 8.4. Presumably, these will have to be justified as 
"additional resources" under NRPM 4.2.4 and be subjected the section 9 
for out-of-region use. Is this correct?

Assuming "justification" for incoming transfers that are intended to be 
used out-of-region is only NRPM 4.2.4, which only looks at existing 
usage, is the actual problem the policy intends to solve the ability to 
transfer or request other space in the future, after using resources 
out-of-region?

Question 4: How does ARIN-2025-3 interact with justifications under 
section 4.5 for multiple discrete networks? Does it impose a requirement 
that all such discrete networks must be in the ARIN region, or does only 
80% of such discrete networks need to be in-region?

I would greatly appreciate it if you, any other AC members, or a policy 
analyst can clarify these matters for me, so we can be better prepared 
to discuss this policy at ARIN 58. It would also allow us to identify 
ways to clarify the NRPM and help ARIN members who are not AC members or 
ARIN fellows to better understand the policies that apply to all of us, 
especially concerning crucial terms like "justification."

Best regards,
Quantum
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