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

[jordi.palet at consulintel.es]

Hi Nonjabulo,

And this is precisely what the proposal is addressing and resolving.

The example that you provide, is not a fake request or an abuse attempt. It is perfectly valid that, for example:

1) I want to build simultaneously not just 2 or 3, but 12 DataCenters.
2) I want to have instead of 4 BGP PoP with PLATs for 464XLAT, 8 of them, because it matches better may actual distribution of the PS core in my mobile network span.
3) Or even 1 + 2 at the same time. If I’ve the money to build all that in order to provide much better service to all my broadband, mobile and hosting customers, why not?

While we have addresses, within the limitation of a /22, why we want to restrict those valid cases as we are doing right now with the existing policy?

The trends calculated by the staff of consumption of IPv4 addresses are clearly telling us that even if every possible AFRINIC member does that, there are still sufficient number of years to go, and because one of the reasons is transitioning to IPv6, it actually means than most probably even before exhaust those addresses, we will have already a sufficient IPv6 deployment so we can return some of those addresses, or even better, they will not be needed by anyone.

Regards,
Jordi

@jordipalet

> El 31 jul 2026, a las 9:26, Nonjabulo Sphilile <nonjabulosphilile at gmail.com> escribió:
> 
> Dear Jordi and colleagues,
> 
> Thank you for the clarification. I want to focus on one issue that is separate from MDN and from the broader debate over the definition of utilisation.
> 
> You say that only the “relevant request” is treated as a first request. That does not resolve the concern. It confirms that the waiver operates independently for each request.
> 
> Nothing in the proposal prevents the same operator from later submitting another qualifying request for a different site, another redundancy deployment, or another IPv6 transition mechanism. The existing CPM also places no explicit limit on the number of additional requests an organisation may submit during the Exhaustion Phase. 
> 
> Consider an operator with existing space below 90% utilisation:
> 
> it requests a /22 for a new site and receives a waiver;
> 
> it later requests another /22 for a second site and receives another waiver;
> 
> it then requests further space for high availability or a transition mechanism.
> 
> 
> Each request may be genuine, properly documented, and individually compliant. No fraud is required. Yet the operator can continue receiving additional space while remaining below the aggregate utilisation threshold that ordinarily protects the remaining pool.
> 
> This is why the staff anti-abuse procedure does not answer the concern. Fraud controls deal with false claims. They do not control cumulative demand arising from several legitimate claims.
> 
> The proposal also contains no requirement that resources received under an earlier waiver must first be deployed for their stated purpose before another waiver may be granted. It evaluates an intended plan at the time of application, but provides no later checkpoint if the project is delayed, cancelled, or materially changed.
> 
> That matters in a finite, first-come-first-served pool. Every legitimate waiver still reduces the space available to new entrants and to operators that have actually reached 90% utilisation. The proposal relies on the recovery of approximately three million addresses to argue that there will be no immediate drain, but it provides no demand model, cumulative limit, inventory trigger, or sunset mechanism. 
> 
> At minimum, the policy should require that:
> 
> a previous waiver allocation be demonstrably deployed before another waiver is considered;
> 
> cumulative waiver allocations be subject to a defined limit or waiting period;
> 
> waiver processing be suspended when the available pool reaches an objective threshold; and
> 
> AFRINIC publish aggregate figures showing the number, purpose, and pool impact of approved waivers.
> 
> 
> The precise limits can follow a staff demand analysis. What should not happen is adopting a repeatable exception first and discovering its aggregate effect only after the remaining pool has been consumed.
> 
> This is not a demand for a perfect policy. It is a request that the policy control the recurrence mechanism it expressly creates.
> 
> For this reason, I remain opposed to AFPUB-2026-IPv4-002-DRAFT02 as presently written.
> 
> Regards,
> Nonjabulo


**********************************************
IPv4 is over
Are you ready for the new Internet ?
http://www.theipv6company.com
The IPv6 Company

This electronic message contains information which may be privileged or confidential. The information is intended to be for the exclusive use of the individual(s) named above and further non-explicilty authorized disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited and will be considered a criminal offense. If you are not the intended recipient be aware that any disclosure, copying, distribution or use of the contents of this information, even if partially, including attached files, is strictly prohibited, will be considered a criminal offense, so you must reply to the original sender to inform about this communication and delete it.