Marty -

We will work to prepare an estimate of the likely costs, but recognize that 
this will be an somewhat uninformed estimate as many of the implications to the 
organization practices will require outside parties (e.g. audit/taxation 
expertise) to fully assess the implications - as noted in the early staff and 
legal review that was conducted:  
https://www.arin.net/participate/policy/drafts/2025_4/#staff-and-legal-review-3-june-2025)

(In addition, we cannot readily determine whether ARIN changing from a 
business-to-business entity to an one that offers services to consumers will 
have any impact to ARIN business practices for our existing customers – such as 
with regards to ARIN’s privacy policy, GST/HST/PST tax treatment, etc. – 
without substantial investment that would not be appropriate at this early 
stage in policy development.)

Thanks,
/John

John Curran
President and CEO
American Registry for Internet Numbers

On Jul 11, 2025, at 3:46 PM, Martin Hannigan <[email protected]> wrote:


A ballpark cost estimate would be helpful.



On Fri, Jul 11, 2025 at 15:42 David Farmer via ARIN-PPML 
<[email protected]<mailto:[email protected]>> wrote:
Doug,

While I agree that expenses should not be the first consideration when 
evaluating policy, at least usually.

Nevertheless, the staff and legal review for this policy, dated June 3rd, 
warns, "Proper implementation will require significant investment to determine 
the full extent of the legal, operational, and compliance adaptations 
necessary, as well as determining resulting implementation cost."

That raises a serious question about what this policy would cost, and not just 
the simple expense of it, but also the legal, operational, and compliance 
consequences to the organization. Those can be boiled down to expenses, but 
from a policy perspective, those are more than just expenses, and the 
consideration of those consequences becomes central to evaluating this policy.

Thanks


On Fri, Jul 11, 2025 at 1:44 PM Douglas Camin 
<[email protected]<mailto:[email protected]>> wrote:
Scott -

I think the intent is to suggest that the community first focus on the merits 
of the policy ahead the costs. This does not mean cost is never a 
consideration, but at this juncture - this draft policy is brand new and only 
received an early staff and legal because of its legal implications - the 
questions to the community revolve around “is this good policy or not."

Hope that helps -


Doug






--
Douglas J. Camin
[email protected]<mailto:[email protected]>
From: Scott Leibrand <[email protected]<mailto:[email protected]>>
Date: Friday, July 11, 2025 at 1:31 PM
To: arin-ppml <[email protected]<mailto:[email protected]>>, Douglas Camin 
<[email protected]<mailto:[email protected]>>
Subject: Re: [arin-ppml] ARIN-2025-4: Resource Issuance to Natural Persons -- 
Request for Feedback

I wholeheartedly disagree. If the benefits of the policy change don’t exceed 
the costs, it’s not good policy. I’m not convinced we haven’t already wasted 
more of our collective time discussing this policy than will ever be saved by 
the small number of individuals who’d benefit from it (those who can’t easily 
apply as sole proprietors).

-Scott
On Jul 11, 2025 at 9:43 AM -0700, Douglas Camin 
<[email protected]<mailto:[email protected]>>, wrote:

Xavier -

Appreciate the feedback and question. When considering policy, it’s encouraged 
to consider the policy exclusively on the merits and not on cost. If it’s good 
policy, it should be implemented and if not, it should be abandoned. This keeps 
us focused on whether policy is sound or not. A sound policy can be expensive, 
and an unsound one can be cheap.

Hope that helps, though I know it doesn’t directly answer your question - we’d 
love to get your feedback on your views on what we should do with the policy.

Thanks!


Doug





--
Douglas J. Camin
ARIN Advisory Council
[email protected]<mailto:[email protected]>

From: ARIN-PPML <[email protected]<mailto:[email protected]>> 
on behalf of Xavier via ARIN-PPML 
<[email protected]<mailto:[email protected]>>
Date: Thursday, July 10, 2025 at 8:33 PM
To: Elizabeth Goodson 
<[email protected]<mailto:[email protected]>>
Cc: [email protected]<mailto:[email protected]> 
<[email protected]<mailto:[email protected]>>
Subject: Re: [arin-ppml] ARIN-2025-4: Resource Issuance to Natural Persons -- 
Request for Feedback


My feedback on this policy depends on what the "implementation cost" 
(referenced in the last paragraph of the Legal Review section) will be. Making 
it easier to access resources is probably worth $10,000 but is probably not 
worth $250,000, IMO. Do we have a ballpark estimate?

Thank you,
Xavier Clark

On Thursday, July 10th, 2025 at 7:27 PM, Elizabeth Goodson 
<[email protected]<mailto:[email protected]>> wrote:
Hello PPML,

I'm shepherding this policy along with Doug Camin. We're seeking direction from 
the community as to how the AC should proceed with this policy. There was 
robust conversation on PPML in late May and early June, which tapered off 
quickly after the ARIN Staff and Legal analysis was published.

https://www.arin.net/participate/policy/drafts/2025_4/#staff-and-legal-review-3-june-2025


Should we
- abandon this policy,
- accept this policy as written, or
- continue to revise this policy?

We appreciate your feedback.

Thanks,
Liz Goodson

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===============================================
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Networking & Telecommunication Services
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