[rpd] [Last Call] Draft Policy Proposal - Soft Landing, Recovered Space and Priority (AFPUB-2026-IPv4-001-DRAFT02)

[Tshepo Masuku]

Dear Jordi and colleagues,

In addition to your response on my previous Last call comment, I observed your separate responses to other members who raised their concerns including Nonjabulo and Fundiswa. I will not repeat their concerns. There is, however, a different issue in DRAFT02 that has not been addressed.

The proposal’s stated problem concerns recovered IPv4 space, Soft Landing irreversibility, and conflicts within the CPM. Yet it also changes two existing twelve-month periods to eight months:

  *   the deadline for reaching 50% utilisation under section 5.5.1.9; and
  *   the SAW period and automatic renewal cycle under section 5.5.1.13.3.2.

These are substantive changes, not editorial corrections.

The first gives operators four fewer months to reach the required utilisation. The second potentially creates three SAW periods within twenty-four months instead of two, allowing the applicable sub-allocation window to refresh more frequently. The proposal provides no evidence explaining why eight months is the correct period, what operational problem the twelve-month period caused, or how the two changes affect depletion of the remaining pool.

The Impact Assessment nevertheless describes the impact on Resource Members mainly as improved CPM readability. That does not account for operators whose deployment and customer-assignment plans were built around the existing twelve-month periods.

The transition is also undefined. For an assignment or SAW already approved before implementation:

  *   does the existing twelve-month period remain valid;
  *   does it immediately become an eight-month period;
  *   does the new period begin on the policy implementation date; or
  *   does the change apply only to new approvals?

Those outcomes have materially different effects. They cannot safely be left to staff sequencing or later interpretation.

Consensus on the treatment of recovered space cannot automatically be treated as consensus on shortening unrelated utilisation and SAW periods. If these changes are necessary, they need their own problem statement, evidence, impact analysis, and transition rule.

I therefore request that the two eight-month amendments be removed from DRAFT02 and considered separately. At minimum, the proposal requires a revised assessment and explicit prospective-application wording.

A possible transition clause would be:

The amendments to sections 5.5.1.9 and 5.5.1.13.3.2 shall apply only to assignments, SAWs, or renewal periods approved after the implementation date. Existing approved periods shall continue under the rules applicable on their approval date.

A later Board review is a safety net, not a substitute for resolving a known normative issue during Last Call.

For this reason, I do not believe DRAFT02 is ready to advance, and I maintain my objection.

Regards,
Tshepo

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