It comes down to the fact that there is a large incentive for consultants to 
push IPv4 reliance as the associated brokerage and leasing agreements that pay 
out commissions. Many of these arrangements even have ongoing payouts for the 
salespersons.

Many of these consultants don’t even have strong backgrounds and networking and 
engineering, but in sales and marketing. Combine that with a lack of knowledge 
on the subject matter for small entrants, and we have what we have now.

This is one tiny inch in the direction that will push the community towards the 
right path on this. I firmly believe educational and information campaigns 
combined with this policy will steer the market in the right direction.

I firmly believe that there are a lot of good consultants out there that do 
exactly as you were saying, and that this is standard practice among a lot of 
them.

Codifying it and making it easier to self service for these small and new 
networks will do a lot to get these networks starting on the right path in 
regards to IPv6 deployment. I think it will be very important to follow up with 
ARIN staff on how this would be implemented on the front end as well.

Preston Louis Ursini
 


> On Sep 22, 2025, at 10:40 PM, Owen DeLong <[email protected]> wrote:
> 
> I’m dismayed that consultants would do that, but I guess there are no 
> shortage of bad consultants out there.
> 
> I’ve been doing effectively SPARK for clients for a long time now (since well 
> before IPv4 runout) and never sent a single client into the leasing realm 
> (despite doing consulting for an IPv4 leasing organization).
> 
> I’ll wait for the proposal to be published as a draft policy before 
> commenting further.
> 
> Owen
> 
> 
>> On Sep 22, 2025, at 20:16, Preston Ursini via ARIN-PPML <[email protected]> 
>> wrote:
>> 
>> Greetings all:
>> 
>> I am seeking community discussion on ARIN-prop-348, the SPARK proposal. 
>> SPARK is intended to create a clear and straightforward entry point for new 
>> organizations needing core Internet number resources. At present, a new 
>> operator must make separate requests for an ASN, IPv4 under section 4.10, 
>> and an IPv6 allocation. Each request has its own requirements, paperwork, 
>> and fees. This complexity has real-world consequences: many small networks 
>> end up turning to consultants who, in practice, often steer them into 
>> leasing IPv4 space instead of working directly with ARIN. That approach not 
>> only increases costs for these new operators but also delays IPv6 deployment.
>> 
>> SPARK grew out of conversations with and feedback from small network 
>> operators in the community. They want to do things “the right way” but face 
>> too many barriers when first approaching ARIN. By creating a single, bundled 
>> policy path, SPARK would make it far easier for them to start off on solid 
>> footing, with an ASN, a /24 of IPv4 from the transition pool, and an IPv6 
>> allocation that is sized for growth.
>> 
>> The benefit of defining SPARK explicitly in the NRPM is that it would give 
>> ARIN staff a clear framework for implementation and provide new operators 
>> with transparency and predictability. It would remove ambiguity, lower entry 
>> costs, and encourage IPv6 adoption from day one. Without a policy like this, 
>> the market incentives push new operators toward leasing arrangements that 
>> solve their immediate IPv4 needs but do nothing to build long-term IPv6 
>> readiness.
>> 
>> I may have confused the historic ASN issuance fee with the current transfer 
>> fee when thinking through the costs, which highlights that ARIN’s fee 
>> schedule could be presented more clearly on the website. That is probably 
>> best addressed through the Consultation and Suggestion Process. The policy 
>> question here, however, is whether we should formally establish SPARK as a 
>> new allocation category in the NRPM, how it should be structured, and what 
>> costs should be attached.
>> 
>> I would greatly appreciate community input on three fronts: where in the 
>> NRPM this category should live, what fee model would be appropriate and 
>> fair, and whether the proposed language around eligibility and resource 
>> sizes needs adjustment.
>> 
>> Thank you in advance for your thoughts and feedback.
>> 
>> All the best,
>> Preston Louis Ursini
>> _______________________________________________
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