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<div class="moz-cite-prefix">Hi Doug,</div>
<div class="moz-cite-prefix"><br>
</div>
<div class="moz-cite-prefix">On 2026-09-25 14:41, Douglas Camin
wrote:<br>
</div>
<blockquote type="cite"
cite="mid:LV9PR13MB7599497EC1B5BFCDBA741DCFDD802@LV9PR13MB7599.namprd13.prod.outlook.com">I
think there may be some confusion about what exactly that proposed
language is bringing about.
<div><br>
</div>
<div>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.)</div>
</blockquote>
<p>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.</p>
<p>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.</p>
<p>Now, let's look through your explanation of the practical
changes:</p>
<blockquote type="cite"
cite="mid:LV9PR13MB7599497EC1B5BFCDBA741DCFDD802@LV9PR13MB7599.namprd13.prod.outlook.com">
<div>For each section, here is the practical change as I can
discern it:</div>
<div><br>
</div>
<div>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.)</div>
</blockquote>
<p>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:</p>
<p>
<blockquote type="cite">ISPs must have efficiently utilized all
allocations, in aggregate, to at least 80% and <b>at least 50%
of every allocation</b> in order to receive additional space.
This includes all space reassigned or reallocated to their
customers.</blockquote>
</p>
<p>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.</p>
<p>Furthermore, is this the only impact on the ability to use the
waiting list? </p>
<blockquote type="cite"
cite="mid:LV9PR13MB7599497EC1B5BFCDBA741DCFDD802@LV9PR13MB7599.namprd13.prod.outlook.com">
<div>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. </div>
</blockquote>
<p>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.</p>
<blockquote type="cite"
cite="mid:LV9PR13MB7599497EC1B5BFCDBA741DCFDD802@LV9PR13MB7599.namprd13.prod.outlook.com">
<div>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.</div>
</blockquote>
<p>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.</p>
<blockquote type="cite"
cite="mid:LV9PR13MB7599497EC1B5BFCDBA741DCFDD802@LV9PR13MB7599.namprd13.prod.outlook.com">
<div>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.</div>
</blockquote>
<p>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:</p>
<p>
<blockquote type="cite">Modify the following text in Section 9:<br>
<br>
FROM:<br>
<br>
IPv4: At least a /22 used in region.<br>
<br>
TO:<br>
<br>
IPv4: At least a /24 used in region.<br>
<br>
Modify the following text in Section 4.2.4.1:<br>
<br>
FROM:<br>
<br>
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.<br>
<br>
TO:<br>
<br>
ISPs must have efficiently utilized all allocations, in
aggregate, to at least 80% <b>inside the ARIN service region</b>
and at least 50% of every allocation in order to receive
additional space. <b>Any requests made when different rules were
in effect remain valid.</b></blockquote>
</p>
<p>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.</p>
<p>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.</p>
<p>Best regards,<br>
Quantum</p>
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