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<p>Good evening,<br>
<br>
I would also like to express my strong opposition to the revised
version of ARIN-2025-3: Change Section 9 Out Of Region Use Minimum
Criteria as written.<br>
<br>
The original version of this proposal, along with its title and
stated purpose, was to reduce the burden on smaller ARIN members
for out-of-region justification of new address space by reducing
the out-of-region justification requirement from a /22 to a /24.
This change, I support, as I believe that requiring small
organizations to acquire a /22 of address space through some means
before they may request out-of-region space is impractical.<br>
<br>
<br>
<br>
Unfortunately, the amended version of the proposal wildly expands
its scope and transforms it into a policy proposal I cannot
support. The revised version of this 'change out of region
eligibility criteria' proposal adds large additional constraints
to other unrelated components of the NRPM and number request
process. More specifically, per my reading, it removes
out-of-region use entirely as justification for *ANY* IPv4
resources requested directly from ARIN and leaves open only the
'transfer market'.<br>
<br>
<br>
<br>
I feel that this amendment to the proposal is difficult to
reconcile with the PDP principle of enabling fair and impartial
number resource administration, under which the Advisory Council
must evaluate this draft. Although many state that the 'transfer
market' is a valid and feasible way to obtain addresses, I believe
some are failing to consider that the 'transfer market' is not a
practical option for the types of organizations that this proposal
purports to support. This is true for a number of reasons,
primarily that IPv4 addresses are expensive. For many small
businesses, being told to find $10k or more to spend on the
transfer market is not a practical answer, and this amendment
would leave them no alternative by closing the standard allocation
path entirely.<br>
<br>
<br>
<br>
To use the waitlist as an example, I do not think ARIN should make
it its policy to categorically exclude a group of operators like
myself (who are willing to work through the waitlist allocation
process and wait for a block to be available) from internet
resources that they have demonstrated a need for, nor should ARIN
be essentially forcing this group to pay exorbitant prices on the
private market. The waitlist is also in effect exclusively used by
'small networks' due to its size restrictions and long wait times.
I suspect that many of those on the list with out-of-region use
cases would be unreasonably harmed by this change, whereas larger
businesses or larger networks that may or may not be eligible for
the waitlist in the first place would have no issue ponying up
$10k for an out-of-region-approved block. I do not see how
excluding a specific subset of entities operating within ARIN's
service region from direct registry service can be described as
fair and impartial administration. </p>
<p dir="ltr">This proposal also makes the unprecedented change of
restricting waitlist eligibility on the basis of the *intended
use* of the addresses requested. Historically, every codified
restriction on waitlist requests has been based on who the
applicant is or what resources they already hold. None have been
based on the purpose of the requested addresses, or how that
organization may choose to utilize them within their
infrastructure. My interpretation of the waitlist's purpose is
that it serves as a catch-all: if you do not qualify for one of
the special-purpose pools, you may still document your need and
wait. This proposal would create the first category of need that
ARIN policy expressly designates as valid justification under
Section 9, but for which ARIN will issue no addresses under any
circumstances.<br>
<br>
<br>
<br>
</p>
<p dir="ltr">I understand that out-of-region use is at best a
secondary priority for ARIN. However, Section 9 already requires a
real and substantial connection to the ARIN service region, so the
organizations affected here are ARIN's own constituents, not
entities shopping for a registry. Directing them to another RIR is
not a costless redirection: obtaining a single /24 from the RIPE
NCC, for example, currently requires establishing and indefinitely
funding an LIR account at roughly EUR 1,800 per year plus a
sign-up fee, for a multi-year wait and a one-time allocation, for
a need they can *already* document to their current RIR (ARIN).<br>
<br>
This policy would also, in effect, create a distinction in the
service offered by ARIN based purely on the amount of resources
(money) the ARIN member is willing to expend. By completely
closing direct IPv4 allocations for out-of-region use, those ARIN
members who have completely legitimate reasons to request space
from ARIN for use outside the ARIN service region would only
receive registry services from ARIN if they were willing to expend
large amounts of money with an unrelated third party. This seems
like a strange and concerning system to introduce in a proposal
intended to help smaller networks.<br>
<br>
<br>
<br>
The amended proposal would also result in the policy directly
contradicting itself, at least to a reader without a legal
background such as myself (emphasis and cuts mine):<br>
<br>
</p>
<div class="moz-cite-prefix">On 8/20/26 11:37 AM, ARIN wrote:<br>
</div>
<blockquote type="cite"
cite="mid:5D98AE43-A1EA-4FE9-B616-DF588A565217@arin.net">
<pre wrap="" class="moz-quote-pre">
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:
[...]
***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>
<p><br>
Although I understand that ARIN policy additionally requires
justification for transferred-in resources, I find the amended
policy to be confusing and contradictory, as it states that
out-of-region use is justification but then excludes all ways of
directly receiving an allocation from ARIN for a specific class of
resources (IPv4). In my eyes, this means that it is in fact not
valid justification. If the community wishes to proceed with this
specific policy (of no longer allowing out-of-region direct
allocations of IPv4 resources to ARIN members), then I would
suggest a rewording is in order, as the policy provides a
'justified use case' for which ARIN bars direct allocations.<br>
<br>
<br>
<br>
To conclude, as others have mentioned, the amended version of this
proposal would, in my opinion, be far better as a set of separate,
narrowly tailored policy proposals, such as the ARIN-2025-8 draft
policy that already exists, rather than as a 'five birds with one
stone' policy proposal that claims to help the very people that
this amended proposal would harm. This amendment essentially
creates two tiers of IPv4 addresses within ARIN policy, which is a
much broader and more complex change than the original text of
this proposal, and presents its own set of challenges and concerns
that should be discussed separately.<br>
<br>
Although I would have supported this proposal as it was originally
written, I cannot support the amended version due to the harm it
would directly cause to small business network operators like
myself, and I must therefore oppose this proposal as it is
written.<br>
<br>
Warmly,<br>
-T<br>
<br>
</p>
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