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<p>Hello,</p>
<p>Please see my comments below:</p>
<p>
</p><blockquote type="cite">
<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>
This draft policy aims to reduce the harm to organizations that wish to use address space outside of the ARIN region, without
currently having a /22 used within the region. This is
understandable and I agree that this is a problem needing to be addressed, as not every organization may have the
capability to use a full /22 within the region before expanding
their network outside of it.<p></p>
<blockquote type="cite">
<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>I can accept the above-quoted text from the proposal as written,
as it aligns with and resolves the problem statement of harming
those with less than a /22 used within the region and requiring
out-of-region use. </p>
<p>
</p><blockquote type="cite">
<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). </pre>
</blockquote>
I cannot agree with the above because it fails to align
with the problem statement provided for the initial proposal, and
as such may actually do more harm than good. This specific
modification as written would restrict ARIN members to obtaining
resources for out-of-region use only through a Section 8 transfer. As
such, this modification has no relation to the initial problem
statement and should be made as part of its own proposal under
the specific NRPM sections to which it applies, if ARIN wishes to
proceed with the change.</div><div><br></div><div>For these reasons, this draft reaches beyond the problem statement by not only addressing the problem being raised but also by adding further restrictions that are out-of-scope of the draft policy's clear goals.</div><div><br></div><div>I strongly oppose this version of the draft policy.<br><br></div><div>Kind Regards,</div><div><span style="background-color:transparent">Peter Potvin</span><p><span style="background-color:transparent">On 2026-08-20 11:37 a.m., ARIN wrote:</span></p>
<blockquote type="cite">
<pre>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:
<a href="https://www.arin.net/participate/policy/drafts/2025_3/" target="_blank">https://www.arin.net/participate/policy/drafts/2025_3/</a>
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:
<a href="https://www.arin.net/participate/policy/pdp/" target="_blank">https://www.arin.net/participate/policy/pdp/</a>
Draft Policies and Proposals under discussion can be found at:
<a href="https://www.arin.net/participate/policy/drafts/" target="_blank">https://www.arin.net/participate/policy/drafts/</a>
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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</pre>
</blockquote>
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