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

[June Slater]

Kaitlyn,

The lack of a specific policy is itself a policy. I understand that what is
written reflects staff interpretation; however, I believe that
interpretation is inaccurate.
Adding an explicit clause to the current policy to match the current
interpretation materially changes the policy, restricting both the options
of opinionated applicants and the room for case-by-case interpretation by
ARIN staff.

I appreciate that community feedback to an ARIN staff question prompted
this policy draft. Absent clear evidence of what I would interpret as
misuse (ex. mass exodus of space to shell corporations for use abroad), I
do not believe this policy change is justified from an impact perspective.
Has there been evidence of this sort of misuse?

I do not believe there is a good way to word the policy while avoiding
ambiguity, exploitability, and complications for legitimate users of the
space.

I remain opposed to the policy proposal.

Regards,
June Slater



On Fri, Sep 18, 2026 at 1:45 PM Kaitlyn Pellak <kaitlyn.pellak at gmail.com>
wrote:

> June and Quantum,
>
> Thank you both for providing your feedback and concerns with this policy.
>
> June I believe your first question is regarding the necessity of such a
> change to 4.10 space. First, I would like to note that IPv4 allocations
> made from 4.10 have historically been interpreted by ARIN staff to be used
> strictly within the ARIN service region. This policy does not intend to
> make any material changes to how 4.10 space is currently being allocated,
> only to make that process explicit to the community by including it
> directly in the Number Resource Policy Manual.
>
> Regarding the need for this change, at the ARIN55 policy meeting the COO
> presented his Policy Implementation and Experience Report. One of the
> topics covered was staff's interpretation of how 4.10 space should be used.
> Specifically, ARIN was looking to understand whether or not the community
> felt that 4.10 space should be allowed to be used outside of the ARIN
> service region. Several community members spoke up in agreement that 4.10
> space should only be used in the ARIN service region. This policy proposal
> was the result of that community feedback.
>
> More broadly, if the opposite path was desired (i.e. to change ARIN
> staff's interpretation of this policy, and make some 4.10 out of region
> usage acceptable) that would likely require an entirely new policy
> proposal. If you would like to see that change made I would strongly
> encourage you to submit a draft proposal, which the Advisory Council would
> be happy to work on with you.
>
> To point two, I can appreciate that the wording seems ambiguous. Is there
> a better wording that you would suggest to make this policy clearer?
>
> I will be noting both of these concerns during the presentation at the
> upcoming Public Policy meeting this October as well. If you are able, I
> would strongly encourage you to please voice these concerns during the
> meeting either at the mic or from online.
>
> Thank you again for your feedback here,
> Kaitlyn
> ARIN Advisory Council Member
>
> On Thu, Aug 20, 2026 at 9:44 PM Quantum via ARIN-PPML <arin-ppml at arin.net>
> wrote:
>
>> On 2026-08-20 16:58, June Slater wrote:
>>
>> 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.
>>
>> Hi June (and cc Owen),
>>
>> I agree with your concerns about the current wording as well as whether
>> this policy is needed in the first place.
>>
>> I want to bring your attention to Draft Policy ARIN-2025-3: Change
>> Section 9 Out Of Region Use Minimum Criteria, which, despite the name, will
>> implement this proposal and more. Thus, if ARIN-2025-8 fails and
>> ARIN-2025-3 passes, your opposition here is for naught.
>>
>> If you oppose ARIN-2025-8, then you must also oppose the current
>> iteration of ARIN-2025-3, as it bans out-of-region justification for
>> sections 4.1.8 waiting list, 4.4 micro-allocations, *and* 4.10 IPv6
>> transition. It's basically ARIN-2025-8 on steroids, bundled into a
>> seemingly unrelated policy.
>>
>> Best regards,
>> Quantum
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