[arin-ppml] Support for ARIN-2025-8 - Reserve 4.10 Space for In-Region Use

[June Slater]

All,

Apologies if this is a resend; I replied to one of these threads in
August of 2025, though my most doesn't seem to have made it into the
archive.

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 Wed, Aug 19, 2026 at 3:34 PM Kaitlyn Pellak <kaitlyn.pellak at gmail.com> wrote:
>
> Hello PPML,
>
> The Advisory Council is seeking support for Recommended Draft Policy ARIN-2025-8: Reserve 4.10 Space for In-Region Use. This recommended draft will be presented at the upcoming meeting in Miami this October. In advance of that meeting we would like to hear from the community whether or not you support this recommended draft as written.
>
> Enthusiastic support is always welcome, but if you do not support this policy it is even more important that you provide that feedback. The AC would also ask that you provide your reasoning and what it would take for you to support this policy, if applicable. Your input here will help us ensure there is community alignment when we present in the fall.
>
> As a reminder, this policy is set to restrict IPv4 addresses governed by section 4.10 to in-region use only. Registration Services have already been enforcing this restriction, the goal of this policy is to align the policy language within the NRPM with the actual implementation by Registration Services.
>
> From the staff and legal review directly:
>
> "The current implementation of Section 4.10 (Dedicated IPv4 Allocations to Facilitate IPv6 Deployment) requires that IPv4 addresses be used within the ARIN region. Draft Policy ARIN-2025-8: Reserve 4.10 Space for In-Region Use codifies the current practices applied by ARIN staff when processing requests under Section 4.10. This policy does not alter existing review practices; it formally documents the longstanding approach ARIN staff has used and will continue to apply."
>
> Thanks!
> Kaitlyn Pellak
> ARIN Advisory Council Member
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