Summary

  • An 11 September Staff and Legal Review says ARIN-2025-3 would bar out-of-region usage as justification for the Waitlist, micro-allocation and IPv6-deployment channels, and marks the draft implementable as written. The policy remains unadopted.
  • On 25 September, ARIN Advisory Council Vice Chair Douglas Camin read the Waitlist change as making the 80% aggregate-use test regional. A same-day reply from Quantum asks whether the separate 50%-per-allocation test is also restricted and why the other two channels are named.
  • The Advisory Council advanced the proposal to Recommended Draft status on 22 September. ARIN’s policy page still lists it as Under Discussion; no applicant outcome or implementation decision is documented.

The latest ARIN-2025-3 exchange turns on the difference between qualifying to request IPv4 space and deciding where that space may be used. On 25 September, Douglas Camin, vice chair of the ARIN Advisory Council, offered a section-by-section reading of the proposal’s new language. He said it concerns the resources that can count toward justification under the Waitlist, micro-allocation and IPv6-deployment provisions. In his reading, it does not expressly prohibit using the requested space outside the ARIN region.

The distinction matters because the proposal now contains more than its original threshold change. The current text would lower the in-region IPv4 utilization threshold in Section 9 from /22 to /24. It also says out-of-region usage justification may not be used to receive IPv4 space through Sections 4.1.8, 4.4 or 4.10, while protecting organisations already on the Waitlist when the policy is implemented. The Advisory Council advanced the draft on 22 September, and ARIN’s policy page identifies its current status as Under Discussion. Advancement is not adoption.

An 11 September Staff and Legal Review on ARIN’s policy page adds an important prior reading. It says Section 9 currently does not apply to Sections 4.4 or 4.10, which have their own restrictions, but that the proposal would expressly bar out-of-region usage as justification for all three named channels. The review marks the draft “Implementable as Written: Yes.” That is an official pre-adoption assessment, not an adopted rule or a record of an applicant decision.

Camin connected the Waitlist clause to existing Section 4 rules. Section 4.1.8.3 says staff assess Waitlist requests against otherwise applicable Section 4 policies. For Internet service providers seeking additional space, Section 4.2.4.1 requires allocations to be used to at least 80% in aggregate and at least 50% for every allocation. Camin reads the relevant 80% utilization as needing to come from use in the ARIN region rather than the applicant’s total global allocations.

He says the micro-allocation route has no written space-based qualification test and that Section 4.10’s utilization criterion matters only for a later tranche after a smaller initial allocation, making the effect there marginal. He presented this as analysis to clarify the discussion, not as advocacy.

That reading does not close every drafting question. In a same-day reply, a participant posting as Quantum said Camin’s explanation could describe the intended effect, but argued the words do not make the boundary clear. The reply asks whether the additional clause also limits the separate 50%-of-each-allocation test and why Sections 4.4 and 4.10 are named if, as Camin reads them, they make little or no practical difference to qualification. Those are a commenter’s questions; they do not establish how ARIN staff would decide a request.

The distinction also tempers the earlier disagreement about support. In its 22 September assessment, the Advisory Council described the proposal as generally supported overwhelmingly, while noting that some participants preferred to eliminate all out-of-region restrictions. The AC said that view did not represent the feedback it considered overwhelming. The published materials provide no vote count or denominator, so the wording should remain attributed to the AC rather than treated as a measured survey or unanimity claim.

The immediate issue is narrower than whether ARIN should permit out-of-region use. The staff review says the added restriction reaches three issuance channels; Camin sees little practical change for two of them, while Quantum questions how the Waitlist’s 80% aggregate and 50%-per-allocation tests interact. Those are different claims about eligibility and implementation, not evidence that an applicant has gained or lost access.

For now, readers can track the policy page, later PPML comments and any revised wording or staff explanation. The process has not reached Board adoption or implementation, and no actual Waitlist decision under the proposed language appears in the sources reviewed here. The next useful evidence would say plainly which test is regional, how the per-allocation threshold interacts with it, and whether that interpretation is part of policy text or later guidance.

Sources: ARIN-2025-3 text, status and 11 September Staff and Legal Review, the current Number Resource Policy Manual, the Advisory Council’s 22 September meeting results, Camin’s 25 September explanation, Quantum’s reply, and the ARIN Policy Development Process.