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Hi Doug (and the other ARIN AC members),
<p>Thanks for answering my questions here and on the Virtual Policy
Open House.</p>
<div class="moz-cite-prefix">On 2026-10-08 09:24, Douglas Camin
wrote: </div>
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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.</div>
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<br>
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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.</div>
</blockquote>
<p>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:</p>
<p>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."</p>
<p>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?</p>
<p>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 <i>current</i> 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.</p>
<p>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 <i>within</i> 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 <i>any</i>
resources, which might be a big lift.</p>
<p>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.</p>
<p>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?</p>
<p>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?</p>
<p>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?</p>
<p>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."</p>
<p>Best regards,<br>
Quantum</p>
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