<!DOCTYPE html>
<html>
<head>
<meta http-equiv="Content-Type" content="text/html; charset=UTF-8">
</head>
<body>
<div class="moz-cite-prefix">Hello,</div>
<div class="moz-cite-prefix"><br>
</div>
<div class="moz-cite-prefix">I am very concerned at the way this
draft policy has been revised and I want to reiterate my
opposition.</div>
<div class="moz-cite-prefix"><br>
</div>
<div class="moz-cite-prefix">On 2026-08-20 11:37, ARIN wrote:<br>
</div>
<blockquote type="cite"
cite="mid:5D98AE43-A1EA-4FE9-B616-DF588A565217@arin.net">
<pre wrap="" class="moz-quote-pre">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.</pre>
</blockquote>
The stated goal of this draft policy is to reduce harm to smaller
organizations in ARIN who have less than a /22 in region and require
some out of region use, as noted here.
<blockquote type="cite"
cite="mid:5D98AE43-A1EA-4FE9-B616-DF588A565217@arin.net">
<pre wrap="" class="moz-quote-pre">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.</pre>
</blockquote>
<p>This part of the proposed policy fulfills that goal and I am not
opposed to it.</p>
<blockquote type="cite"
cite="mid:5D98AE43-A1EA-4FE9-B616-DF588A565217@arin.net">
<pre wrap="" class="moz-quote-pre">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.</pre>
</blockquote>
<p>This part of the draft policy has nothing to do with the stated
goal and represents a fundamental change to ARIN's allocation
policy, not an adjustment to the minimum criteria for NRPM section
9 per the title and stated goal of the draft policy. This should
not be added as an amendment to a policy.</p>
<p>We have entire policy proposals like <a
href="https://www.arin.net/participate/policy/drafts/2025_8/">ARIN-2025-8</a>,
which only prohibits the out-of-region use of NRPM section 4.10,
that changes less than this <i>amendment</i> to the draft policy.
In fact, if the current draft of ARIN-2025-3 passes, it would
render ARIN-2025-8 completely pointless and all the objections to
it moot.</p>
<p>Given the broad scope of this change and how it has <i>nothing</i>
to do with the stated goal, this provision should be a <b>separate</b>
policy so that the community can properly participate and debate
the merits of the change. It should <b>not</b> be bundled as an <b>amendment</b>
to a policy draft whose name and stated goal has nothing to do
with the provision. This prevents the ARIN community from properly
debating the policy change and I cannot in good conscience support
this.</p>
<p>Also, the portion that blanketly prohibits out-of-region usage
justifications for the ARIN Waiting List (section 4.1.8) has
massive implications. Unlike the reserved pools under section 4.4
and 4.10, there are currently no limitations to the potential uses
of ARIN resources from the waiting list outside of those that
apply to all IPv4 resources under NRPM section 4, only on the
amount of space to ensure a fair allocation. As such, users of the
ARIN waiting list can currently benefit from the full suite of
services provided by ARIN.</p>
<p>Under this proposal, users of the ARIN waiting list (or any
reserved pools) will no longer be able to access the out-of-region
justification, meaning that the <i>only</i> way to acquire new
IPv4 resources for out-of-region use would be through a section 8
transfer, which in practice, means acquiring resources from a <i>third-party</i>
that is not the ARIN member or ARIN itself. It means that the full
suite of ARIN's services will no longer be accessible without a
third-party willing to transfer resources, which in practice
requires paying such parties large sums of money. I find this
change very concerning, as members will no longer be able to
access the full scope of ARIN's services by dealing with ARIN
itself.</p>
<p>Furthermore, the stated goal of the policy is to reduce "harm" of
smaller ARIN organizations who wishes to use resources out of
region. Recall under NRPM section 4.1.8 that:</p>
<p> </p>
<blockquote type="cite">Organizations which hold more than a /20
equivalent of IPv4 space in aggregate (exclusive of special use
space received under section 4.4 or 4.10) are not eligible to
apply.</blockquote>
<p></p>
<p>In effect, this means that all ARIN members who use the waiting
list are small organizations in the grand scheme of things. By
prohibiting the ability of such small organizations to use the
waiting list, it forces them to acquire IPv4 resources from the
market, which is a lot more costly than the waiting list. In
essence, this policy <i>harms</i> small organizations that hold
between a /22 and /20 of IPv4 space.</p>
<p>This harm is not necessary to accomplish the stated goal of this
draft policy. There is also, to my knowledge, no known influx of
out-of-region requests on the waiting list from ARIN organizations
holding between a /22 and /20 that justifies such an intervention.
So why are we penalizing this group of ARIN organizations when
they have done no wrong? For a policy that's supposed to reduce
harm, it just harms a <i>different</i> group of ARIN members for
no good reason.</p>
<p>In conclusion, the current formulation of Draft Policy
ARIN-2025-3 contains provisions that have nothing to do with the
stated goal of the policy, and these provisions have wide-reaching
consequences and inflict direct and unnecessary harm on a
different group of small ARIN members. I firmly oppose this
version of the policy.</p>
<p>Best regards,<br>
Quantum</p>
</body>
</html>