Quantum - Apologies, it took me a while to follow up on your response.
I'm glad that the exchange helped build a better understanding about this policy. The items you've brought up are definitely part of the feedback and input that the shepherds will be taking into account. The suggested changes below are also helpful; it's great to have concrete language suggestions. I'll defer to the shepherds and their role in the process but offer the reminder that in a few weeks we have the next public policy meeting (ARIN58) in Miami. The policy will be presented from the stage and live feedback solicited from the community. I encourage you to participate (virtually or in person) if possible. Thank you! Doug From: ARIN-PPML <[email protected]> on behalf of Quantum via ARIN-PPML <[email protected]> Date: Friday, September 25, 2026 at 5:41 PM To: [email protected] <[email protected]> Subject: Re: [arin-ppml] Recommended Draft Policy ARIN-2025-3: Change Section 9 Out Of Region Use Minimum Criteria Hi Doug, On 2026-09-25 14:41, Douglas Camin wrote: I think there may be some confusion about what exactly that proposed language is bringing about. In the example you have built, you said that the change forbids you from getting any space for out of region use. I don’t believe that interpretation is correct. The language in this proposal only applies to what resources you can use to count towards the required justifications to receive the space under 4.1.8, 4.4, or 4.10. There is no explicit prohibition on where to use that space (though, separately Recommended Draft policy 2025-8 will modify 4.10 to explicitly state it is to be used in the ARIN region.) Since you are the vice chair of the ARIN Advisory Council, I assume your understanding of the intention of what the policy is meant to accomplish is correct. However, that intention differs from the way I understood the policy. Since I was able to come to a different interpretation of the policy text, then it suggests that the policy text is poorly worded. After all, if I can interpret it in such a way as to reject any request of IPv4 space for out-of-region use, then ARIN staff may interpret it incorrectly down the line, which is a result that no one wants. Now, let's look through your explanation of the practical changes: For each section, here is the practical change as I can discern it: 4.1.8 Waitlist - As currently written, if you have a /20 or more of space already, you would not be able to access the waitlist anyhow. But, if you have less than that you are subject to the clause in 4.1.8.3 about other applicable policies, which takes you to 4.2.4.1 Utilization percentage (80%.) Currently, that /21 or below can be in any region and still qualify for justification to get on the waitlist. The new restriction will limit the justification to get on the waitlist to being able to demonstrate an entity is using 80% of their current allocations in the ARIN region (as opposed to their total global allocation.) Assuming that the section 9 changes are meant to specifically restrict the 80% utilization percentage in 4.2.4.1 to count only the allocation used in region, this makes sense. However, section 4.2.4.1 states, in its entirety: ISPs must have efficiently utilized all allocations, in aggregate, to at least 80% and at least 50% of every allocation in order to receive additional space. This includes all space reassigned or reallocated to their customers. It is not clear how that "at least 50% of every allocation" part isn't restricted by the proposed language in section 9. If it is restricted, then it becomes impossible to request additional space under the waiting list as long as you have used any space out-of-region, which doesn't seem like the intention. This is another source of confusion. Furthermore, is this the only impact on the ability to use the waiting list? 4.4 Micro-allocation - There is currently no written space-based qualification criteria in 4.4 that is evaluated, the justification is whether or not an entity is critical infrastructure, regardless of their space usage and where it is located. The new restriction does not explicitly appear to change the materiality of how to qualify and would not currently impact this section. Why is section 4.4 explicitly named in the policy text if it doesn't have any material effect? It just adds to the confusion. 4.10 v4 -> v6 Deployment - 4.10 has criteria outlining who qualifies but the only time a usage justification comes up is if you get less than a /22 initially and wanted the remainder to be allocated later. Bullet 3 says if you received smaller than a /22 (ie, /24) and wanted more (ie, another /24) you have to demonstrate 80% usage of what you have - so the new language would require that usage to be in the ARIN region. That is a nominal change, because its unclear you could use the initial /24 outside the region and obtain the next /24 anyhow. So the new restriction does not explicitly appear to materially change the initial qualification, but it could have a marginal impact on the second step in an corner case scenario. I agree that if the policy change only restricts subsequent allocations for section 4.10, then this is unlikely to have any effect. In which case, I also question the need to enumerate section 4.10 in the policy text. To summarize all of the above (hopefully) succinctly: The language of this policy proposal is speaking only to the criteria to justify qualifying for sections 4.1.8, 4.4, and 4.10. This language will not add restrictions to how you can utilize the space. The language will have an impact on how entities can qualify for 4.1.8, and will not have an impact on how they qualify for 4.4 or 4.10 space. The additional language was added based on input from the community requesting those clauses be added, and has been in line with the trend in recent years to explicitly clarify that any remaining allocations of v4 space from ARIN are expected to be used in the ARIN region. These changes do not impact the ability of an entity to get space from the transfer market and use it as they see fit. Now that I fully understand your intentions behind the policy and examples of how it should apply, I think this would be a clearer way of framing the policy: 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. Modify the following text in Section 4.2.4.1: FROM: ISPs must have efficiently utilized all allocations, in aggregate, to at least 80% and at least 50% of every allocation in order to receive additional space. TO: ISPs must have efficiently utilized all allocations, in aggregate, to at least 80% inside the ARIN service region and at least 50% of every allocation in order to receive additional space. Any requests made when different rules were in effect remain valid. Per your analysis, this is the actual impact of the policy change, so we might as well make the change where it matters, and not rely on spooky action at a distance inside section 9. Is this alternative version of the policy text materially the same per your understanding? If so, I believe it to be a lot clearer than the current policy and we should use this version instead. Best regards, Quantum
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