Hello Michael,

Thank you for your response, and your support of this proposal.

Based on some of your comments in your email, it appears that there may be a 
slight misunderstanding of how policy and the fee structure works - account 
fees are based on the size of their holdings - e.g. if an account holder has a 
/23 v4 ($1709/year) and a /32 v6 ($2256/year), the account holder would pay the 
higher of the two. In this case, they would pay the $2256 per year.

Also, it is not APNIC who creates these policies - it is the community through 
the Policy Development Process who forms these policies. I as the proposer 
present the policy proposal to the community, it is discussed (as we are now) 
and if it reaches consensus at both the OPM and AMM it then goes to the EC for 
endorsement. If it is endorsed, it is then sent to the Secretariat for 
implementation. If it does not reach consensus at either the OPM or AMM, it 
goes back to the mailing list for further discussions.

Finally, it is outside the scope of the PDP to consider account fees when 
discussing policy and proposals.

Regards,
Christopher Hawker

P.S. For anyone who is interested in how the APNIC community shapes and forms 
policy through the PDP, I recommend attending the Policy 101 session at APRICOT 
2026 on 09 Feb at 15:30 UTC+7:00. It's a great way to learn more and get a feel 
for how it works. For more info, check out 
https://2026.apricot.net/programme/programme#/day/6/146/.
________________________________
From: Michael Williams via SIG-policy <[email protected]>
Sent: Monday, 2 February 2026 10:23 AM
To: Satoru Tsurumaki <[email protected]>
Cc: [email protected] <[email protected]>
Subject: [sig-policy] Re: prop-168: Increase to maximum IPv4 delegations

We support this policy change for organisations that presently only hold a /23 
and pay the same rates as those holding a /22. It seems silly that it's taken 
APNIC this long to produce such a sensible policy. We implore the passing of 
this policy to increase maximum IPv4 delegations to /22.

Regards,

Michael Williams



________________________________

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Glexia - An IT Company

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On Wed, Jan 28, 2026 at 22:11:20, Satoru Tsurumaki 
<[email protected]<mailto:[email protected]>> wrote:

Dear Colleagues,

I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.

I would like to share key feedback in our community for prop-168, based on a 
meeting we organized on 22nd Jan to discuss these proposals. Please note that 
it is a summary of the discussions among the 11 Japanese community members who 
attended the meeting.

Many opposing opinions were expressed from the attendees about this proposal.

(comment details)
- The proposal states that expanding the maximum allocation size would allow 
organizations that need additional addresses to avoid transfers or leasing. 
However, addressing leasing-related issues by changing the allocation size does 
not appear to be an appropriate approach.

- Several proposals to modify IPv4 allocation sizes have been submitted in the 
past,
and there is a sense of fatigue regarding repeated discussions of this topic. 
Greater effort should be directed toward IPv6 deployment rather than continued 
debate over IPv4.

- From a policy perspective, it is undesirable for allocation sizes to vary 
depending on
the time period. This proposal may simply accelerate IPv4 exhaustion by a few 
years.

- According to APNIC’s transfer request list, only around 10% of organizations 
request
address blocks of /23 or smaller. Therefore, it is unlikely that this proposal 
would often
lead to additional allocations for organizations whose historical maximum 
allocation was /23.

- Expanding the allocation size while reserving a new /16 pool for transfers 
appears
inconsistent with the stated objective of distributing addresses more broadly.

- If expanding the allocation size demonstrably reduces reliance on leasing, 
then support
for the proposal would be warranted.

Regards,

Satoru Tsurumaki
JPOPF Steering Team

2025年12月18日(木) 10:12 顧靜恆 <[email protected]<mailto:[email protected]>>:

Dear SIG members,

A new proposal "prop-168-v001: Increase to maximum IPv4 delegations" has been 
sent to the Policy SIG for review.

It will be presented at the Open Policy Meeting (OPM) at APNIC 61 on Wednesday, 
11 February 2026.

https://2026.apricot.net/programme/programme#/day/8/

We invite you to review and comment on the proposal on the mailing list before 
the OPM.

The comment period on the mailing list before the OPM is an important part of 
the Policy Development Process (PDP).

We encourage you to express your views on the proposal:

Do you support or oppose this proposal?

Does this proposal solve a problem you are experiencing? If so,

tell the community about your situation.

Do you see any disadvantages in this proposal?

Is there anything in the proposal that is not clear?

What changes could be made to this proposal to make it more effective?

Information about this proposal is appended below as well as available at:

https://www.apnic.net/community/policy/proposals/prop-168

Regards,

Bikram, Shaila, and Ching-Heng

APNIC Policy SIG Chairs

-------------------------------------------------------------------------------

prop-168-v001: Increase to maximum IPv4 delegations

-------------------------------------------------------------------------------

Proposers:

Christopher Hawker ([email protected]<mailto:[email protected]>)

1. Problem statement

-------------------------

As of 09 December 2025, there were 3,142,656 IPv4 addresses (12,276 x /24) in 
the available pool [1].

Since prop-127 was implemented back on 04 April 2019 there were 549 new members 
in 2025 (as of 03/12/2025), 667 new members in 2024 [2],

904 in 2023 [3], 824 in 2022 [4], 783 in 2021 [5], 827 in 2020 [6] and 841 in 
2019 [7] (noting that this also includes Q1 2024 which was prior to 
implementation of prop-127).

At the current average of 727 new member accounts per year, and if each member 
was to apply for the maximum delegation of /23,

the delegation rate would be approximately 1454 x /24 per year, meaning the 
pool will be exhausted in 2035.

This means that resources will sit idle in the available pool for an extended 
period (up to 9 years), while current members are required to acquire

additional space through market transfers or lease address space to meet 
operational requirements.

2. Objective of policy change

----------------------------------

Current address policy only allows for the maximum delegation of up to and 
including a /23 to new and existing members.

This policy change will allow organisations who became members since the 
implementation of prop-127 and with less than an aggregated /22 to receive an 
additional

delegation of up to a maximum of a /22 IPv4 delegation.

3. Situation in other regions

--------------------------------

- The maximum size aggregate a member in the ARIN region may qualify for at any 
one time a maximum is a /22 [8].

- "The sum of all allocations made to a single LIR by the RIPE NCC is limited 
to a maximum of 256 IPv4 addresses (a single /24)." [9]

- Exhaustion Phase 2 (section 5.4.3.2) in AFRINIC's Consolidated Policy Manual 
states that the "maximum will be /22 per allocation/assignment" [10].

- LACNIC's Policy Manual lists under section 11.1.4 "Policies Relating to the 
Exhaustion of IPv4 Address Space" that the maximum size a new member may

receive is a /22, while under 11.1.2 it states that existing members are 
ineligible for additional space under this policy [11].

4. Proposed policy solution

--------------------------------

Update "APNIC-127 APNIC Internet Number Resource Policies" with the below:

- Delete paragraphs 2 and 3 from section 6.1 "Minimum and maximum IPv4 
delegations", and replace with the following:

Members who hold less than a /22 may apply for additional space, to bring their 
combined holdings up to and including a /22.

Members who have transferred any IPv4 address space of any size out of their 
member account are ineligible for further delegations from APNIC.

- Delete paragraph 4 from section 11.0 "IPv4 Transfers", and replace with the 
following:

Addresses delegated from the available pool cannot be transferred for a minimum 
of five years from the date of delegation.

If a member received an initial delegation and applies for a subsequent 
delegation, all delegations to the member cannot be transferred for a minimum 
of 5 years

from the date of the most recent delegation.

- Update point 4 from paragraph 1 under section 11.1.1 "Conditions on the space 
to be transferred" as below:

Addresses delegated from the available pool cannot be transferred for a minimum 
of five years from the date the original delegation was made.

If the source entity received a delegation from APNIC within the last 5 years, 
any resources delegated from the available pool (including those delegated over 
5 years ago)

cannot be transferred for a minimum of 5 years from the date the most recent 
delegation was made.

- Delete paragraph 3 from section 11.2.1 "Conditions on the space to be 
transferred" and replace with the following:

Some RIRs, including APNIC, have restrictions against the transfer of certain 
address blocks.

APNIC policy does not allow the transfer of address space delegated from the 
available pool to be transferred for a minimum of five years from the date of 
the most

recent delegation to the member.

- Delete paragraph 2 from section 14.0 "Mergers & Acquisitions" and replace 
with the following:

Addresses delegated from the available pool cannot be transferred for a minimum 
of five years from the date of the most recent delegation from the available 
pool.

- Add new section 5.1.5 "Reservation for IPv4 to IPv6 Transitioning":

APNIC will reserve a /16 from the available pool, for the purpose of delegating 
to members in order to assist with IPv4 to IPv6 transitioning once the 
available pool

has been exhausted. Addresses delegated from this pool are ineligible for 
transfers, and must be returned to APNIC when no longer required.

If a member receives a delegation under this policy and is found to not be 
using the address space for IPv4-to-IPv6 transitioning, APNIC may recover the 
resources from the member.

5. Advantages / Disadvantages

------------------------------------

Advantages:

- This will help to make additional resources available to members who need it, 
that would otherwise need to acquire space through market transfers or lease 
address space.

Disadvantages:

- This policy will accelerate the exhaustion of IPv4 address space, however, 
given the slow rate of new memberships

the benefits of additional space becoming available to members outweigh the 
disadvantages of accelerated exhaustion.

- This may create a sudden rush of members in applications for additional 
resources, leading to extended waiting times for the assessment of applications.

6. Impact on resource holders

-----------------------------------

No known impacts to resource holders.

7. References

----------------

[1] APNIC Delegation Statistics as of 09 December 2025: 
https://ftp.apnic.net/stats/apnic/2025/delegated-apnic-extended-20251209.gz

[2] Page 22, APNIC 2024 Activity Report: 
https://www.apnic.net/wp-content/uploads/2025/02/APNIC-AR-2024.pdf

[3] Page 19, APNIC 2023 Activity Report: 
https://www.apnic.net/wp-content/uploads/2024/02/APNIC_AR_2023.pdf

[4] Page 17, APNIC 2022 Activity Report: 
https://www.apnic.net/wp-content/uploads/2023/05/APNIC_AR_2022_FINAL.pdf

[5] Page 17, APNIC 2021 Activity Report: 
https://www.apnic.net/wp-content/uploads/2022/03/APNIC_AR_2021.pdf

[6] Page 18, APNIC 2020 Activity Report: 
https://www.apnic.net/wp-content/uploads/2021/03/APNIC-2020-Annual-Report.pdf

[7] Page 30, APNIC 2019 Activity Report: 
https://www.apnic.net/wp-content/uploads/2020/02/APNIC-AR-2019-FINAL.pdf

[8] ARIN Waitlist, Number Resource Policy Manual, ARIN: 
https://www.arin.net/participate/policy/nrpm/#4-1-8-arin-waitlist

[9] Allocations made by the RIPE NCC to LIRs, IPv4 Address Allocation and 
Assignment Policies for the RIPE NCC Service Region, RIPE NCC: 
https://www.ripe.net/publications/docs/ripe-826/#51-allocations-made-by-the-ripe-ncc-to-lirs

[10] Soft Landing, Consolidated Policy Manual, AFRINIC: 
https://afrinic.net/policy/manual#Soft-Landing

[11] Policies relating to the Exhaustion of IPv4 Address Space, LACNIC Policy 
Manual: 
https://www.lacnic.net/innovaportal/file/680/1/manual-politicas-en-2-21.pdf

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--
Satoru Tsurumaki
BBIX, Inc
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