[rpd] [Last Call] Draft Policy Proposal - Hierarchical Names for New AS-SETs (AFPUB-2026-ASN-001-DRAFT02)

[tshepo mavhungu]

Dear Policy Development Working Group,

I would like to express my concerns regarding the proposal to introduce
hierarchical naming for new AS-SETs (AFPUB-2026-ASN-001-DRAFT02).

I agree with the concerns raised by Fundiswa, Thandeka, and Nonhlanhla
during the discussion.

At first glance, this proposal appears to be a minor technical enhancement.
However, policy changes should be evaluated not only on their immediate
operational benefits, but also on whether they expand institutional
complexity or shift the role of the registry beyond its core function.

The primary role of the registry is to maintain an accurate, neutral, and
reliable resource registry and associated data infrastructure. Policy
should focus on preserving the integrity of the ledger and enabling
operational continuity, rather than continuously introducing new structures
that may increase dependence on registry-defined conventions.

One concern is that proposals of this nature, while well-intentioned, can
contribute to what has been described as “mandate laundering”: the gradual
expansion of institutional influence through incremental policy changes
that appear administrative or technical in isolation, but collectively
increase the scope of centralized governance over network operations and
coordination practices.

The Internet’s resilience comes from minimizing unnecessary dependencies
and preserving operator autonomy. If hierarchical AS-SET naming is
genuinely required for operational efficiency, the proposal should clearly
demonstrate that existing mechanisms are insufficient and that the benefits
outweigh the costs of additional policy complexity. Convenience alone is
not a sufficient basis for expanding registry-managed structures.

This also relates to the broader “stability fallacy”: the assumption that
more structure, more policy, or more institutional mechanisms necessarily
create more stability. In many cases, long-term stability is better served
by simplicity, interoperability, and clear separation between registry
administration and operator decision-making.

The burden of proof should therefore rest with proponents to demonstrate
that this proposal addresses a concrete operational problem that cannot be
solved through existing practices, voluntary coordination, or tooling
improvements outside the policy framework.

For these reasons, I do not support the proposal in its current form and
encourage the Working Group to prioritise minimalism, operational
continuity, and the protection of the registry’s core mandate.

Kind regards,

Tshepo Mavhungu
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