Hi All,

 • I support or oppose the proposal.
 • I think it's clear as-is.
 • I don't see any changes necessary for it to be more effective.

As a provider of services in maritime safety and environmental telemetry, my 
business is tied to IPv4 for many years to come. Our customers and data 
interconnection partners run very conservative, old systems.  We have been 
impacted by the /23 cap. Fortunately due to sparse allocation on the part of 
APNIC there's an adjacent /23 unallocated we could request to supplement our 
network.

It's clear the secondary market for v4 is functional, but it is expensive. I 
don't see much benefit in APNIC dribbling out the rest over the next nine 
years, and I do see some harm to existing APNIC members done by the current 
policy. This change would fix that harm.

Regards,

Jon

On Mon, 10 Aug 2026, at 22:39, Christopher Hawker wrote:
> Hello Arash,
> 
> Thank you for sharing your feedback on the proposal, I appreciate your 
> feedback and suggestions. To address your suggestions:
> 
> On the topic of a phased rollout, to my knowledge the Secretariat currently 
> operate (and I believe if prop-168 is adopted would continue to operate) on a 
> First-In-First-Out basis, that is, applications would be processed in the 
> order in which they are received. If there is a concern that this could 
> affect response times which in turn would affect SLAs for application 
> processing, the Secretariat may review and adjust their SLAs, or if approved 
> by senior management exempt subsequent resource requests from SLA metrics. 
> This, to my knowledge, would sit outside the scope of INR policy.
> 
> As for genuine M&As, the change to 14.0 was primarily for consistent wording 
> throughout the policy document. The intent of this change (as is also the 
> case based on my understanding) is that if an account holder receives a 
> subsequent delegation, and is then merged into or acquired by another account 
> holder and the request is indeed legitimate, all resources transferred in 
> from the losing account holder would not be transferrable for 5 years from 
> the date of the most recent delegation to the losing account holder.
> 
> To give you an example of how prop-168 would tie in with M&As (to use RFC1918 
> space in this example as there are no documentation prefixes larger than a 
> /24):
> 
>  1. ACME Internet receives the allocation 192.168.0.0/23 from APNIC on 01 
> July 2024.
>  2. Prop-168 reaches consensus during the Policy SIG meeting and AMM, is 
> implemented, and becomes policy.
>  3. On 13 March 2027, ACME Internet receives a second /23 (that they applied 
> for a few weeks earlier) as permitted under policy, meaning that the earliest 
> they can transfer any of their resources out of their account is 13 March 
> 2032, when the 5-year transfer lock expires as the clock on 192.168.0.0/23 
> was reset when they received their subsequent delegation.
>  4. On 27 August 2029, Bigger Broadband acquires 100% ownership of ACME 
> Internet, and makes the decision to transfer all resources from ACME 
> Internet's account across to theirs. The resources that came across from ACME 
> to Bigger would still be subject to the original transfer lock expiration 
> date of 13 March 2032 as these resources are *transferred*, not *delegated*.
> The Secretariat is permitted to request sufficient evidence to demonstrate 
> that the merger or acquisition is legitimate for the purpose of transfers 
> under existing M&A policy. This would help to prevent "sham acquisitions" 
> whereby falsified or fraudulent documents are provided in an attempt to 
> circumvent the 5-year transfer lock for market transfers.
> 
> Regards,
> Christopher Hawker
> 
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