Kat -

That’s an excellent reminder - Let me jump in here and be fairly specific in 
the concerns:

a)  Terminology: best to avoid term "grandfathering in” – it’s unnecessary 
gerontological terminology so just omit.

b)  Regarding handling existing entries on the wait list – be explicit 
regarding their handling if changing policies that affect wait list processing. 
 Entries on the list can be handled differently (out of respect for existing 
status) or may handled according to updated policy – just be clear about the 
intention either way.

Thanks!
/John

John Curran
President and CEO
American Registry for Internet Numbers


On Jul 13, 2026, at 1:42 PM, Kat Hunter <[email protected]> wrote:

I would highly recommend removing any language that refers to "grandfathering 
in". Perhaps "will be exempt until they are removed from the waitlist" but 
grandfathered in will not pass a staff and legal/community review. We have seen 
this turned down for a number of reasons in the past.

Kat Hunter
Comcast/AC Chair


On Mon, Jul 13, 2026 at 12:54 PM Tom Fantacone via ARIN-PPML 
<[email protected]<mailto:[email protected]>> wrote:
Correction - my last sentence should have read:

"Using the term "transfer market" as in Option 1 is bound to create ambiguity 
since the term is not defined anywhere in the NRPM."

Speaking of ambiguity...




From: Tom Fantacone via ARIN-PPML 
<[email protected]<mailto:[email protected]>>
To: "Gerry George"<[email protected]<mailto:[email protected]>>
Cc: "ARIN PPML"<[email protected]<mailto:[email protected]>>
Date: Mon, 13 Jul 2026 10:48:48 -0600
Subject: Re: [arin-ppml] Request for Comment & Feedback: Draft Policy 
ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria

Gerry,

Thanks for the clarifications.

I support the policy as written in Option 2.  It's very clear and explicit.

Using the term "transfer market" as in Option 2 is bound to create ambiguity 
since the term is not defined anywhere in the NRPM.

Regards,

Tom Fantacone



From: Gerry George via ARIN-PPML <[email protected]<mailto:[email protected]>>
To: "ARIN PPML"<[email protected]<mailto:[email protected]>>
Date: Mon, 13 Jul 2026 08:11:45 -0600
Subject: [arin-ppml] Request for Comment & Feedback: Draft Policy ARIN-2025-3: 
Change Section 9 Out Of Region Use Minimum Criteria




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Good day and greetings, ARIN community.

We had a suggestion for some modified text to the Draft Policy, primarily in 
response to feedback and reactions from ARIN 57 and PPML discussions, as many 
of the concerns related to potential gaming of the system to access the ARIN 
address pool for out-of-region use.  The brief background and suggested change 
text is as follows:

As a reminder, this proposal is to 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.

The intent is to amend the proposal, including text to specifically exclude out 
of region usage as justification to get IPv4 from the waiting list.
Suggested text - Option 1:


Out of Region usage justification can only be used to acquire IPv4 addresses 
from the transfer market.  Any organization on the Waiting List at the time 
this policy is implemented will be grandfathered-in.

Suggested text - Option 2:

Out of Region usage justification may not be used to receive IPv4 addresses 
from the ARIN Waitlist (4.1.8), Micro-allocation pool (4.4) or Dedicated IPv4 
Allocation to facilitate IPv6 Deployment (4.10).  Any organization on the 
Waiting List at the time this policy is implemented will be grandfathered-in.

The first option is shorter, and does not specifically refer to ARIN reserve 
pools, which could change.  The second option does not include the term 
“transfer market”.  That term does not appear in the NRPM, and directly 
mentions the waiting list.

The full change to the policy will thus be:
Problem Statement

Section 9<https://www.arin.net/participate/policy/nrpm/#9-out-of-region-use> 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<https://www.arin.net/participate/policy/nrpm/#9-out-of-region-use>:

FROM:
IPv4: At least a /22 used in region.
TO:
 IPv4: At least a /24 used in region.

ADDITIONAL TEXT:
Out of Region usage justification can only be used to acquire IPv4 addresses 
from the transfer market.
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.
[Organizations on the Waiting List at the time this policy takes effect shall 
be exempted and will not be affected by this change.]
OR
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.
[Organizations on the Waiting List at the time this policy takes effect shall 
be exempted and will not be affected by this change.]

Note the text in square brackets suggests the intent of the last sentence, and 
may be considered for substitution for brevity.


Please submit your comments of support, dissent, encouragement or disapproval 
for the policy, and for the proposed text changes.


Regards


Gerry E. George
ICT Consultant and Business Solutions Architect;
DigiSolv, Inc. [P.O. Box 1677, Castries, Saint Lucia]
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