[arin-ppml] Draft Policy ARIN-2025-8: Reserve 4.10 space for In-Region Use

[June Slater]

1. I'm unsure if the change is necessary; it feels
unnecessarily protective. Has there been an influx in requests to use 4.10
space out of the region? Especially given ARIN's current practice of
requiring entities to be in-region, this feels like it would primarily
impact a small-subset of users.
This is especially true given NPRM section 9, which would necessitate an
entire /22 of space being used in-region. If an entity were only using 4.10
space, they'd need to put in a pretty substantial amount of time and effort
for relatively little reward.
Some scripting on the ftp file suggests roughly 17.8% of 4.10 space has
been allocated (with only 26 entities having more than a /22 or more of
4.10 space); while that's not nothing, the burn rate doesn't seem
particularly concerning to me. A few allocations for out of region use (to
in-region entities) doesn't feel problematic.

2. Echoing Owen's concerns, the wording seems ambiguous. The staff
interpretation seems to have deviated into the intent and not the actual
wording - facilitating deployment within the service area is not
necessarily the same as being used within the service area.
Given how ambiguous 4.10 already is (and how it necessitates judgement
calls from ARIN staff), I'm concerned at the possibility of introducing yet
more ambiguity.

Absent data showing a need, opposed in principle. Regardless, opposed as
written.

Regards,
June Slater

On Tue, Aug 26, 2025 at 11:29 AM ARIN <info at arin.net> wrote:

> On 21 August 2025, the ARIN Advisory Council (AC) accepted “ARIN-prop-347:
> Reserve 4.10 space for In-Region Use” as Draft Policy.
>
> Draft Policy ARIN-2025-8: Reserve 4.10 space for In-Region Use
>
> https://www.arin.net/participate/policy/drafts/2025_8
>
> You are encouraged to discuss all Draft Policies on PPML. The AC will
> evaluate the discussion to assess the conformance of this draft policy with
> ARIN's Principles of Internet number resource policy as stated in the
> Policy Development Process (PDP). Specifically, these principles are:
>
> * Enabling Fair and Impartial Number Resource Administration
> * Technically Sound
> * Supported by the Community
>
> The PDP can be found at:
>
> https://www.arin.net/participate/policy/pdp/
>
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/participate/policy/drafts/
>
> Regards,
>
> Eddie Diego
> Policy Analyst
> American Registry for Internet Numbers (ARIN)
>
>
>
> Draft Policy ARIN-2025-8: Reserve 4.10 space for In-Region Use
>
> Problem Statement:
>
> ARIN 4.10 allocations, reserved to facilitate IPv6 deployment, currently
> have no restrictions for out-of-region use beyond the general restrictions
> laid out in Section 9. As the use of these allocations outside of the ARIN
> region seems to be contrary to the intentions for use of this space - and
> ARIN staff has interpreted the policy as such - the prohibition of this
> practice should be codified in policy.
>
> Policy Statement:
>
> Change the second sentence in NRPM Section 4.10 from:
>
> “This IPv4 allocation will be set aside and dedicated to facilitate IPv6
> deployment.”
>
> to:
>
> “This IPv4 allocation will be set aside and dedicated to facilitate IPv6
> deployment within the ARIN service area”
>
> Comments:
>
> This proposal was prompted by community feedback to Registration Services,
> as reported in the ARIN 55 Policy Experience Report. ARIN staff has
> indicated that there is no intention to extend this restriction to 4.10
> allocations assigned before the implementation of this policy.
>
> Timetable for implementation: Immediate
>
>
>
>
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