I am not In favor of this proposal. I believe one of the major hurdles 
discussed previously was the inability for an individual to receive an ASN 
through any means other than via ARIN. Looking at the draft problem statement 
this is not actually made clear. I would propose a different policy be proposed 
with a different problem statement be written that directly addresses this 
issue. Something along the lines of "Current ARIN policy restricts the 
assignment of ASNs to be issued directly via ARIN. This policy aims to reduce 
this restriction such that LIRs/ISPs may reassign ASNs as part of their 
Internet services". I'm not a great wordsmith, this needs more thought. ARIN 
maintains its B2B nature and the burden for B2C transactions is placed at the 
LIR who would maintain the direct relationship with ARIN and be subject to its 
normal fee schedule. Then any individual can go to the LIR and procure the 
service, granted that they meet the normal technical requirements of 
assignment. To get an idea of what would need to be updated I asked an AI tool 
to see what would be a good starting point and it came up with this.

## Policies Requiring Update

To permit an LIR to assign both IP addresses and ASNs to 
individuals—effectively enabling individual subscribers to act as autonomous 
network operators—the following ARIN policies would need to be revised:

1. **Assignment and Allocation Distinctions:**

- Current language restricts "assignments" of resources to end-users who are 
*not* eligible to further sub-allocate or operate as fully independent resource 
holders. Policy must be updated to allow LIRs to assign IP space and ASNs to 
individual subscribers for their own autonomous use.

2. **Utilization and Justification Requirements:**

- Utilization requirements and technical justification must be modified to 
allow justification based on individual assignments, even for small-scale or 
residential use.

3. **ASN Allocation Policies:**

- Presently, ARIN issues ASNs directly to organizations/individuals who justify 
a unique routing policy, not to LIRs for indirect assignment. Policy must 
explicitly permit LIRs to assign (as opposed to reallocate) ASNs to their 
individual customers.

4. **Reassignment Registration and Privacy:**

- Reassignment rules must be clarified to provide streamlined SWIP or database 
documentation procedures and suitable privacy protections for individual 
resource holders.

### Key NRPM Sections Likely Affected

- Section 2.4: Definitions—LIR, ISP, End-User

- Section 4.2 & 4.3: Assignments/Reassignments to End-Users

- Section 6.5: IPv6 Allocations and Qualifications

- Section 6.5.5: Registration Requirements

- Section 7: Autonomous System Numbers (ASN)

## Sample Policy Update Language

Below is proposed amendment language. Use ARIN’s format for policy proposal 
clarity, traceability, and relevance:

### 1. NRPM Section 2.4 – Local Internet Registry (LIR)

**Current:**

> A Local Internet Registry (LIR) is an IR that assigns IP addresses to the 
> users of the network services it provides...

**Update:**

> A Local Internet Registry (LIR) is an IR that assigns IP addresses and, when 
> justified, Autonomous System Numbers (ASNs) to its users, including 
> organizations or individuals, for use either as part of the LIR’s network or 
> as independent, fully autonomous networks, as permitted by policy.

### 2. NRPM Section 4.3 & Section 6.5.8 – End-User Assignments

**Current:**

> End-users may only receive assignments for use within their internal networks 
> and not for sub-delegation...

**Update:**

> LIRs may assign IP address space or ASNs to individual subscribers or 
> organizations for their exclusive use, provided each subscriber demonstrates 
> a bona fide technical need and agrees to ARIN’s utilization, stewardship, and 
> reporting standards. Such assignments may be made for the purpose of 
> customers operating independently routable networks.

### 3. NRPM Section 7 – Autonomous System Numbers

**Current:**

> ASNs are assigned directly by ARIN to organizations demonstrating a unique 
> routing policy.

**Update:**

> ARIN may allocate ASNs to LIRs for assignment to their individual subscribers 
> or customers who provide technical justification for a unique routing policy. 
> LIRs must maintain records of assignments and make them available to ARIN 
> upon request.

### 4. NRPM Section 6.5.5 – Registration

**Add:**

> LIRs assigning individual resources (IP addresses, ASNs) to end-user 
> subscribers must register such assignments in the ARIN database, in 
> accordance with customer privacy guidelines set forth in Section 3.3 and 
> Section 4.2.3.7.3.2.

## Table: Policy Change Summary

| Area                | Current Policy Limit          | Required Change         
              |

|---------------------|------------------------------|---------------------------------------|

| LIR Assignments     | Only to users of services    | To individuals as full 
resource holders|

| ASN Assignment      | Direct by ARIN to org/ind    | LIR may assign to 
customer with need  |

| Utilization         | Aggregated, per infra/user   | Explicit for individuals 
as networks  |

| Registration/SWIP   | Org-based, privacy rules     | Individual, robust 
privacy mechanisms |

## Considerations

- **Fee Plan:** Fee structure may also need adjustment for per-individual 
assignments.

- **Abuse & Stewardship:** Safeguards must ensure assignments are justified, 
efficiently utilized, and do not encourage resource hoarding or abuse.

**In summary:**

A comprehensive NRPM revision is necessary—spanning assignment eligibility, 
technical justification, ASN allocation, registration, and privacy—to permit 
LIRs to assign resources (IPs and ASNs) to individuals as autonomous operators, 
rather than only as users within a provider’s infrastructure.

Obviously more thought needs to go into this but this should help provide a 
base to start with to address this problem statement.

[ [email protected] ~]$ cat .signature
cat: .signature: No such file or directory
[ [email protected] ~]$ cat .disclaimer
All opinions are my own and do not represent any of my employer.
[ [email protected] ~]$ cat .pronouns

He/Him

Sent via Superhuman ( https://sprh.mn/[email protected] )

On Thu, Jul 10, 2025 at 7:26 PM, Elizabeth Goodson < 
[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
> (
> 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
> 
> 
> _______________________________________________
> ARIN-PPML
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> Please contact info@ arin. net ( [email protected] ) if you experience any
> issues.
> 
> 
>
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