Hello Satoru,
Thankyou for the feedback from the Japanese community. I note that the JPOPF-ST held their meeting on the same day that version 2 of the proposal was released. When the policy proposal was discussed, were the discussions based on version 1 or version 2 (in which the Secretariat's impact assessment was considered and concerns addressed)? I'll address your concerns based on version 1 being reviewed.
Regarding the concerns relating to the definition of "commercial purpose" and "commercial in nature", in essence if an organisation applies for resources under this policy they cannot use them for any purpose which is considered "for-profit", i.e. they cannot be used for financial gain or benefit in any form. For example, what would be considered "for-profit" are purposes where the applicant intended to use the resources to supply services which yield the organisation a financial gain, an entity charging a fee to attend a conference where the intent is to promote and/or advertise proprietary services and systems, or private education providers charging a tuition fee to students in order to derive a monetary benefit for the entity providing the education. What would not be considered commercial is where the applicant uses the resources for training programs held by not-for-profit organisations recognised by a government body in their home economy that educate participants on operational technologies, conferences held by Network Operator Groups where the overall nature of the conference is non-profit in nature, or special interest groups which hold meetings to discuss functions, systems and protocols that benefit the wider community.
In forming this proposal, I did look at the number of cases where this policy could benefit, however, as a policy of this nature has (to my knowledge) never been implemented in the APNIC service region where organisations can request resources for temporary purposes aligned with this proposal, it is rather difficult to gauge. It is worth mentioning though, that should this proposal reach consensus and it is implemented, and in 1-2 years the community feels that this proposal is no longer fit for purpose, it can be repealed or amended with the resources returned to the available pool.
In relation to the concerns about the resources in use by APRICOT and APNIC, the proposal does not impact any existing assignments or allocations, not just those in use by APRICOT and APNIC for the conferences they hold. The purpose of this proposal is to allow for a /21 IPv4 prefix, a /29 IPv6 prefix as well as 8 AS numbers to be reserved by APNIC for purposes specified in this proposal. To be clear, it is not designed (and the proposal does not allow) for the reclamation of existing delegations. AS24555, 220.247.144.0/20 and 2001:df9::/32 were delegated under existing policy and therefore are not affected by this proposal.
Are the sizes of the prefixes reserved under this policy enough to fill anticipated use-cases? To be transparent I do not know. Existing policy does not allow for delegations therefore it cannot be gauged whether a /21 IPv4 prefix and /29 IPv6 prefix will be sufficient. As mentioned earlier, this can be amended through future proposals if required. Does the JPOPF feel that a larger pool is required, or is this a general question?
Unfortunately, I do disagree with the comment that "it is impossible to establish such a standard criteria" regarding what is considered commercial and non-commercial use. The general concept of what is considered commercial use, is the use of a tangible or intangible item or thing for financial gain which I believe can be applied to any economy. I was able to quite easily come up with three examples of what is considered commercial and what is not. It is virtually impossible to establish an exhaustive list of what is considered a commercial purpose which is why examples were given to form a guide for the Secretariat in making a determination. Section 5.8.2.4 under the Proposed Policy Solution was designed to be a "catch-all" which allows applicants to submit a request and for the Secretariat to grant these allocations for purposes which we may not be able to think of, however may be a strong use-case.
If the Japan Open Policy Forum has any recommendations or suggestions as to how this proposal could be improved, please do let me know. I thank you and appreciate the feedback.
Regards,
Christopher Hawker
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