ARIN-prop-341: NRPM section 9, out of region use

Date: 13 February 2025

Proposal Originators: Eddie Stauble

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 current text in 9. from:

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 /22 used in region 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

To:

IPv4: At least a /24 used in region 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

Comments: In my experience when a company needs address space outside of the ARIN region without at least a /22 in region, they go to RIPE and acquire either PI or Legacy space (the least expensive option), often acquiring the space from ARIN sources.

In the case of an inter-regional ARIN to RIPE transfer, RIPE does require the recipient to demonstrate need, as required by ARIN. ARIN is losing registration of the block and annual fees, as well as the recipient transfer fee. Most of these recipients would much rather keep everything together in one ARIN account instead of having to go to another registry.

Looking back over the history of Section 9, it was first proposed by Terri Stumme in PROP 189 in May 2013, and was abandoned.

The Second proposal was by David Farmer in PROP 192 in January 2014 and was abandoned. .

The third proposal was by Christian Tacit in PROP 219 in May 2015. It became draft policy ARIN-2015-5, implemented July 2016. The AC Shepherds were Tina Morris and David Huberman.

In looking over the discussions of the proposals, there was a concern before ARIN ran out of addresses in 2015 that foreign entities would set up shell companies in the ARIN region, looking for free addresses. Since ARIN is out of address space, that fear is no longer valid. If there is a fear of swindling the already crowded waiting list, it might be prudent to ban out of region needs demonstration from the waiting list.

There was a fear of the additional expenses and complexity involved in verifying out of region use. Since the policy has been in effect for almost 9 years, what has ARIN’s experience been in verification of out of region use? Is out of region use invoked often? Are there any statistics as to how often it is denied due to less than a /22 used in region?

There were also concerns expressed about unlimited out of region use. There is a lower limit on in-region use, but there is no upper limit to how much space can be used out of region, as long as you have a /22 in region. Has this been a problem?

The current policy requirement of a /22 in region appears to be arbitrary, and is detrimental to and discriminates against smaller entities.

Timetable for Implementation: Immediate