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[Nonjabulo Sphilile]

Dear PDWG,

I have reviewed AFPUB-2026-IPv4-002-DRAFT02 against the current CPM and the
concurrent Soft Landing, Recovered Space and Priority proposal. I wish to
raise one specific issue that does not appear to have been addressed.

DRAFT02 amends only section 5.4.6.1. However, the current CPM contains
separate utilisation requirements in sections 5.5.1.4.1, 5.5.1.4.2, and
5.6.3.

This means an operator could qualify for a waiver from the 90% requirement
under DRAFT02 but still fail the existing 80% LIR threshold, the rule
excluding future reservations from valid utilisation, or the separate PI
utilisation requirements.

The concurrent Soft Landing proposal proposes deleting those provisions,
and its Impact Assessment says their removal will assist integration of
this amendment. In contrast, the Impact Assessment for DRAFT02 records no
interaction with other proposals.

Those positions need to be reconciled.
Before rough consensus is determined, AFRINIC should publish a combined
interpretation explaining the outcome where:
only AFPUB-2026-IPv4-002 is adopted;
only AFPUB-2026-IPv4-001 is adopted;
both are adopted;
and the two are implemented on different dates.

The treatment of future utilisation also remains undefined. If an
allocation granted under the waiver is intentionally underutilised for
redundancy or high availability, will it form part of “all prior
allocations or assignments” when the operator submits its next request?
If it remains in the denominator, one waiver may create continuing
dependence on further waivers. If it is excluded, the proposal creates a
separate class of resources outside the normal utilisation calculation. The
policy currently states neither result.

There is also a timing issue in relying on approximately three million
recovered addresses to justify the change. Recovered inventory is not
necessarily immediately allocable inventory. The effective date should be
supported by the amount actually available after quarantine and by a demand
and depletion analysis.

These are not demands that the proposal solve every possible future
problem. They concern the rule that applicants and Hostmasters will
actually be required to apply from the implementation date.
A policy governing a finite pool should be internally consistent,
measurable, and capable of producing the same result from the same facts.
At present, DRAFT02 depends on another unresolved proposal, leaves future
utilisation accounting undefined, and relies on inventory that may not yet
be available.

For these reasons, I do not believe the proposal is ready to advance and I
object it.

Regards,
Nonjabulo
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