[arin-ppml] Draft Policy ARIN-2025-6: Fix formula in 6.5.2.1c

[John Curran]

> On Feb 18, 2026, at 12:52 PM, Owen DeLong <owen at delong.com> wrote:
> 
>> On Feb 18, 2026, at 07:10, John Curran <jcurran at arin.net> wrote:
>> 
>> 
>>> On Jul 14, 2025, at 10:48 AM, Owen DeLong via ARIN-PPML <arin-ppml at arin.net> wrote:
>>> 
>>> Assuming /48 as the PAU is not true to the policy. The policy was intended to encourage LIR/ISPs to implement /48 PAUs by limiting the size of allocations to providers that issued smaller end site allocations.
>> 
>> Owen -
>> 
>> If a provider were to indicate during its initial IPv6 request that it intends to use a smaller minimum end-user allocation size, the policy can operate as you describe. In that case, staff will explain the impact that customer allocation size has on serving site calculations and overall qualification. If the ISP chooses to adopt a larger provider allocation unit, that will be reflected in the justification and the resulting allocation.
>> 
>> That said, ARIN does not control what providers ultimately deploy as their end-user allocation size. Further, two of the qualification paths for subsequent expansions of IPv6 allocations do not involve the minimum provider allocation unit at all.
>> 
>>> It saddens me to learn that ARIN has implemented the policy in a manner that contravenes the clear language of the policy defining PAUs.
>> 
>> As Mr. Sweeting noted, staff do discuss customer allocation size and its implications with first-time IPv6 requestors. All ISPs receive at least a /32 IPv6 allocation unless they request less, and the serving-site calculation primarily affects those seeking more than a /32 in their initial allocation. Note that subsequent allocations may be justified without application of the provider allocation unit, for example a single serving site exceeding 90 percent utilization.
> 
> Said utilization should be calculated based on applicable PAU,  no?

Owen - 

Calculation of utilization is based on actual network reality.  If they meet the criteria for additional space then their existing allocation is expanded if possible; if it is not possible, then they expand by getting a new allocation based on the initial allocation criteria calculation (i.e. “the smallest nibble-boundary aligned block that can provide an equally sized nibble-boundary aligned block to each of the requesters serving sites large enough to satisfy the needs of the requesters largest single serving site using no more than 75% of the available addresses.” - again, ignoring the incorrect summary formula) 

>>> I sincerely hope ARIN will correct this, though at this point, it’s likely too late to have meaningful impact.
>> 
>> There is nothing to correct, unless you wish ARIN to engage in enforcement activities against ISPs that don’t meet your expectations of minimum allocation unit.
>> 
>> For example, if an existing ISP should decide to lower their minimum customer allocation unit from /56 to /60, are you suggesting that ARIN seek rejustification of their present IPv6 resource holdings?  We can only go on information provided during the initial request, and have not been directed by the community to meddle in their ongoing customer engineering decisions in the manner you seem to suggest.
> 
> I certainly expect that to be used in determining “utilization” rate in a subsequent request. I also expect ARIN to do something about cases of deliberate misrepresentation.

See above - you have to show that your actual utilization meets one of the three criteria specified in 6.5.3.(b) ("Subsequent Allocations to LIRs”) 

> When ARIN makes a provider aware of the implications of selecting a smaller PAU, do they make it clear that the provider is expected to live up to their stated PAU or do they imply as you have above that any fig leaf will do?

I’ve reviewed the policy text carefully with regard to ARIN’s role in the ongoing policing of provider network engineering decisions, and alas I am coming up empty.

ARIN requires accurate requests for number resources, we tell organizations that their requests must be accurate, and organizations engaging in deliberate misrepresentation are taking some serious risks as ARIN will revoke resources issued as a result of fraudulent requests. 

>>> For example, a certain large $CABLECO in the US issued /60s to their residential customers, so their PAU should be assumed to be /60 and not /48.
>> 
>> See above – If indeed the community wants ARIN more involved in enforcement of provider minimum allocation size, that can be done but would need to be quite explicit in policy given the consequences that could result.
>> If that’s not the case, then the current policy text suffices – and is being implemented as written, aside from known incorrect “summary formula”.
> 
> Does ARIN look at misrepresentations of PAU as they would any other material misrepresentation on an initial request?


Network providers should make faithful representations when requesting number resources, and this applies regardless of request type.  As noted, in all cases, intentional misrepresentation can result in revocation of the issued number resources.

Thanks,
/John

John Curran
President and CEO
American Registry for Internet Numbers