Apologies all that first bullet should read: "I support the proposal". 

On Mon, 17 Aug 2026, at 11:20, Jonathan Brewer wrote:
> 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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> 
> https://jon.brewer.nz/
> 
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