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(see the python-dev thread [1])
(related: issue #32086)
When I consolidated the global runtime state into a single global, _PyRuntime, calls Py_DecodeLocale() started to break if the runtime hadn't been intialized yet. This is because that function relies on PyMem_RawMalloc() and PyMem_RawFree(), which rely on the raw allocator having been initialized as part of the runtime (it used to be intialized statically).
The documentation for various "Process-wide parameters" [2] explicitly directs users to call Py_DecodeLocale() where necessary. The docs for Py_DecodeLocale(), in turn, explicitly refer to calling PyMem_RawFree(). So changing the pre-runtime-init behavior of Py_DecodeLocale() and PyMem_RawFree() is a regression that should be fixed.
[1] https://mail.python.org/pipermail/python-dev/2017-November/150605.html
[2] https://docs.python.org/3/c-api/init.html#process-wide-parameters