Dear Policy Dave, SIG Chairs, and Community, Thank you for the Secretariat's detailed review and impact assessment of prop-165-v003.
We appreciate the constructive feedback and the effort invested in analysing the proposal and its implementation implications. We would like to provide the following clarifications and possible refinements for community consideration. - Monitoring use of IPv4 resources for IPv6-only network support The intent of this proposal is not to create a new continuous compliance monitoring framework or require APNIC to actively inspect network operations. Our expectation is that applicants would submit an IPv6-only Deployment Declaration describing: - the planned IPv6-only deployment; - the transition-related services requiring IPv4 connectivity; and - the intended use of the requested IPv4 /24. In response to the Secretariat's question regarding how APNIC might determine whether the resources continue to support an IPv6-only deployment, we believe a declaration-based approach supplemented by reasonable evidence may be sufficient. Historically, APNIC has assessed specialised policy requests by requesting evidence of operational requirements. For example, during the transition from 2-byte to 4-byte ASNs, applicants seeking continuation of a 2-byte ASN could be required to demonstrate that they operated equipment or software that was not compatible with 4-byte ASNs. A similar approach could be applied here. Where necessary, APNIC may request supporting evidence that the member operates IPv6-capable infrastructure or services associated with the declared IPv6-only deployment. The authors do not expect APNIC to perform technical audits or ongoing operational monitoring. Instead, any review should remain lightweight and declaration-based. To further clarify this intent, the authors are considering replacing: > "must be used solely to support IPv6-only network operations and related transitional functions" with: > "must be used primarily to support IPv6-only network operations and related transitional functions, as described in the applicant's deployment declaration." - Clarification regarding reassignment The phrase: > "must not be permanently reassigned to another organisation" was intended only to prevent transfer of control of the resource to another legal entity. It was not intended to establish a distinction between permanent and temporary reassignment. To remove ambiguity, we propose replacing this text with: > "must not be transferred, reassigned, or otherwise made available for use by another organisation." This wording more clearly reflects the intended policy objective. - Clarification regarding periodic review The periodic review mechanism is intended to be lightweight and administrative in nature. The review would be limited to confirming that: - the associated IPv6 allocation remains valid; - the IPv6-only deployment remains operational; and - the delegated IPv4 resources continue to be required for transitional purposes. Where necessary, APNIC may request an updated IPv6-only Deployment Declaration and supporting information relevant to the deployment. No detailed utilisation calculations, host-count justifications, or technical inspections are intended. - Clarification regarding the Sunset Provision We agree with the Secretariat that additional specificity would assist implementation. The current proposal uses a forecast-based trigger: > APNIC projects that the IPv4 address space available for delegation under the Final /8 Policy will be exhausted within six months, based on the average allocation rate during the preceding twelve-month period. We continue to believe this is an objective and transparent mechanism. However, an alternative approach may be to maintain a fixed reservation from the remaining Final /8 pool. For example, the policy could cease issuing new delegations when the available Final /8 pool falls below a reserved operational threshold, such as a /15 equivalent of IPv4 address space. Such an approach may provide a simpler and more predictable implementation model because it relies on an absolute inventory threshold rather than a forecast of future consumption. The authors welcome community input regarding whether: - a forecast-based threshold; - a fixed-reserve threshold; or - a combination of both would be more appropriate. - Applications in progress We agree that applications already under assessment should be addressed explicitly. The authors propose: > Applications approved prior to activation of the sunset condition shall > continue to be processed normally. > > Applications that have not yet been approved at the time the sunset condition > is activated shall be assessed under the policies then in force. - Operational impact We acknowledge that implementation would require APNIC to: - identify delegations made under this policy; - link them to the qualifying IPv6 allocation; and - support a declaration-based review process. However, the Secretariat notes that only approximately 1.2% of APNIC members held IPv6 resources without IPv4 resources as of 30 June 2026. Given the limited target population and the restriction of one /24 per eligible organisation, we expect the operational impact to remain relatively small. - Conclusion The authors thank the Secretariat for the detailed assessment. Based on this feedback, we are considering revisions that: - clarify that review is declaration-based; - permit supporting evidence where appropriate; - remove ambiguity regarding reassignment; - simplify and clarify the sunset mechanism; - define handling of applications already in progress; and - minimise operational overhead while preserving the policy objective of supporting IPv6-only deployment. We look forward to further discussion from the community. Kind regards, Tomohiro Fujisaki Hiroki Kawabata Authors, prop-165 2026年8月18日(火) 8:59 Dave Phelan <[email protected]>: > > Dear SIG Members, > > Please find below the Secretariat impact assesment for prop-165-v003 : > Provision of IPv4 Address Space to IPv6-only Networks for Transitional Purpose > > > > Dave Phelan > > Policy Manager and Senior Network Analyst > > > > ----- > > 1. APNIC’s Understanding of the Proposed Policy > > APNIC understands this proposal as allowing members that hold an IPv6 > allocation to request one IPv4 /24 delegation for IPv6-only network > transition purposes. > > The proposal is expected to affect a limited number of members. APNIC > Secretariat notes that, as of 30 June 2026, 1.2% of APNIC members held IPv6 > but not IPv4. > > The proposal states that the IPv4 block must not be permanently reassigned to > another organisation. > > > > 2. Impact of Proposed Policy on Registry and Addressing System > > Registry systems would need to identify IPv4 /24 delegations made under this > policy, link them to the member’s IPv6 allocation, and apply the specific > policy conditions. > > Additional clarification may be needed on whether these blocks can be > temporarily reassigned or sub-assigned, given the proposal only prohibits > permanent reassignment > > The following question from the previous assessment still remain outstanding > > How should the Secretariat monitor if their IPv4 is being used to support > their IPv6-only network and not being used for some other purpose? > > 3. Impact of Proposed Policy on APNIC Operation/Services > > APNIC would need to create an assessment process for requests under this > policy and provide guidance on how to conduct periodic reviews. > > The Secretariat is requesting guidance on how they should periodically check > whether the IPv4 resources remain necessary for transitional purposes. > > The sunset provision requires further clarification before implementation. > The proposal includes three separate triggers: projected exhaustion of the > Final /8 pool within six months, a community-determined minimum threshold, > and a determination by the APNIC Executive Council that continued operation > would materially threaten equitable access to remaining IPv4 resources. > > APNIC would need a clear operational method for applying these triggers, > including how exhaustion projections are calculated, how often they are > reviewed, what data is used, and how the result is published. The proposal > does not currently define the community threshold, which would need to be > specified before that trigger could be implemented. > > The EC-based trigger would also require clarification, including the criteria > for making such a determination, whether the suspension of new delegations is > temporary or permanent, and how this interacts with the normal policy process. > > 4. Legal Impact of Policy > > We note that the phrase ‘permanently re-assigned’ implies some form of > reassignment may be allowed, provided it is not permanent. It would be > helpful to understand if there is a deliberate intention behind this to guide > our interpretation and the development of corresponding procedures. > > The Proposed Policy will require a number of amendments to APNIC-127, however > the specific implementation of such changes has not been made clear by the > Authors. This uncertainty may create a number of enforcement and assessment > challenges depending on its implementation, which can be considered further > following clarification of the Secretariat’s questions in other parts of this > impact assessment. > > 5. Implementation > > Implementation would require clarification of the sunset mechanism, including > the calculation method for projected exhaustion, the value and form of the > community-determined threshold, and the process for any EC determination. > APNIC would also need to define how applications in progress are handled if a > sunset condition is triggered. > Until such point as these clarifications are made, we are unable to make a > determination on implementation process and time frames. > > _______________________________________________ > SIG-policy - https://mailman.apnic.net/[email protected]/ _______________________________________________ SIG-policy - https://mailman.apnic.net/[email protected]/ To unsubscribe send an email to [email protected]
