[rpd] [Last Call] Draft Policy Proposal- Amendment of Utilisation in Soft Landing AFPUB-2026-IPv4-002-DRAFT02

[ALAIN AINA]

Dear Co‑chairs,

The proposal, as currently written, remains vulnerable to several forms of abuse and does not align with the principles of responsible resource management, fairness, or predictability in policy application.

On 15 June 2026, I proposed a more robust and technically grounded solution to the problem the proposal attempts to address, through a Multiple Discrete Networks (MDN) architecture with strict per‑site utilisation rules instead of global per‑organisation utilisation. Reference: https://lists.afrinic.net/pipermail/rpd/2026/014894.html 

The author responded that MDN issues “may also happen in the region” but stated that this proposal is not intended to fix that problem. Reference: https://lists.afrinic.net/pipermail/rpd/2026/014895.html  

- Staff analysis and PPM discussions

++ Member Services (Section 3.3.4)

Staff highlighted the need for anti‑abuse provisions in operational procedures to allow identification of fraudulent requests. This confirms that the proposal’s current language is insufficiently constrained.

++ PPM discussions

According to the PPM minutes:

    • A concern was raised that the policy language is too broad and therefore subject to abuse. The author responded:“…if the community later determines that staff are exercising too much discretion or using this flexibility inappropriately, the policy can be amended or clarified through future community action.”

    • A concern was raised regarding the absence of a clear, objective definition of “utilisation” within the PDP. The co‑chairs committed that the Secretariat would share this definition during Last Call. To my knowledge, this definition has not yet been shared. 
Reference: https://afrinic.net/ppm-afrinic-37.html 

- Specific issues with the current text

1. Waiver criteria are extremely broad

The proposal allows AFRINIC to waive the 90% utilisation requirement for:
    • redundancy
    • high‑availability
    • IPv6 transition
    • expansion to new sites
These are legitimate technical needs, but easy to claim without evidence, making the clause vulnerable to abuse.

2. “Key technical purposes” is undefined
The phrase is subjective and lacks operational meaning. Without a definition, Hostmasters must rely on interpretation, leading to:
    • inconsistent decisions
    • appeals
    • pressure from members
    • accusations of unfairness

3. “Sufficiently documented” is unenforceable
The proposal does not specify:
    • required documentation
    • required evidence
    • required topology diagrams
    • required utilisation metrics
    • required thresholds
This makes enforcement arbitrary and unpredictable.

4. Treating the request as a “first allocation” resets utilisation
This is the most problematic clause.

It allows:
    • utilisation to reset to 0%
    • bypassing the 90% rule entirely
    • repeated claims of “new site” or “redundancy”
    • accumulation of multiple /22s without ever reaching 90% utilisation

This is a major abuse vector and contradicts responsible resource management.

- Possible solution (fully resolves the utilisation barrier)

A predictable, enforceable solution exists and has already been proposed:

1. Replace global utilisation with per‑site utilisation (MDN model)
This aligns with real network architecture (multi‑PoP, multi‑DC, HA NAT, NAT64/464XLAT) and global RIR practice.

2. Remove “treated as first allocation”
This closes the most significant loophole.

3. Replace the waiver with a structured MDN section
This ensures that exceptions are based on verifiable technical constraints, not subjective interpretation.

4. Define strict evidence requirements
For example:
    • topology diagrams
    • BGP announcements
    • NAT64/HA NAT architecture
    • per‑site utilisation metrics
    • proof of disaggregation
    • proof of IPv6 transition deployment

5. Allow per‑site redundancy headroom
To support HA and failover, allow sub‑allocation to any MDN site at 85% utilisation instead of 90%.


This approach is technically sound, operationally enforceable, and consistent with the principles of fairness and responsible resource management.

Regards,

—Alain

> On 16 Jul 2026, at 22:08, Hytham El-Nakhal <hytham at tra.gov.eg> wrote:
> 
> Dear PDWG,
> 
> 
> Last Call: Amendment of Utilisation in Soft Landing (AFPUB-2026-IPv4-002-DRAFT02)
> 
> 
> The Policy Development Working Group (PDWG )Chairs  have initiated a Last Call for this proposal, following rough consensus at the AFRINIC-37 Public Policy Meeting held in hybrid format in Nairobi, Kenya on 24 June 2026.
> 
> 
>  *   Proposal Name: Amendment of Utilisation in Soft Landing
> 
>  *   Proposal ID: AFPUB-2026-IPv4-002-DRAFT02
> 
>  *   Proposal URL: https://www.afrinic.net/afpub-2026-ipv4-002-draft02.html
> 
> .
> 
> Last Call closes on : July 31, 2026, at 23:59 UTC.
> 
> 
> The Secretariat will provide an operational definition of "utilisation" during this period to assist with final community review.
> 
> 
> As always, we kindly request that all participants adhere to the AFRINIC Code of Conduct<https://www.afrinic.net/code> to maintain a respectful and professional environment on the mailing list.
> 
> 
> Kind regards,
> 
> 
> Haitham el Nakhal
> 
> AFRINIC PDWG Co-Chair
> 
> 
> 
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