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

[Tshepo Masuku]

Dear Jordi and colleagues,

I want to raise an issue separate from MDN, repeated waiver requests, and the general definition of utilisation.

You describe the Member Services procedures mentioned in section 3.3.4 as an implementation matter. However, if those procedures determine whether a request genuinely qualifies as redundancy, high availability, IPv6 transition, or expansion to a new site, then they determine who is eligible to receive scarce address space.

That is not merely workflow. It is a substantive allocation rule.

The proposal therefore creates a difficult choice. If the future procedure remains flexible, different staff members may reach different conclusions on similar requests. If the procedure becomes strict and detailed, AFRINIC staff will effectively have written the real qualification criteria after the policy has already passed.

The absence of recommendations in the Impact Assessment does not resolve this. A policy can be technically implementable while still being unpredictable. Staff may be able to process applications, but applicants cannot know in advance what evidence will satisfy the rule, and any appeal body will have no published standard against which to test consistency.

Before this proposal advances, AFRINIC should publish the actual decision framework required to implement it. That framework should use representative cases and identify the minimum evidence, acceptance criteria, grounds for refusal, reasons that must be recorded, and review process. If those elements determine eligibility, they should form part of the policy or be expressly incorporated into it, with material changes returning for community review.

This is not a demand to predict every future network design. It is a request that the rule governing access to a finite pool be visible before AFRINIC begins enforcing it.

Otherwise, the PDP approves broad language while the operative policy is written later through internal procedure. That transfers the real decision from the community-reviewed text to continuing staff discretion.

For that reason, I do not believe DRAFT02 is ready to advance.

Regards,
Tshepo



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