Update of PDP
Details
| Name of Proposal |
Update of PDP |
Status: | Under Discussion |
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ID: |
AFPUB-2026-GEN-005-DRAFT01 |
Date Submitted: |
14/10/2026 |
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Author(s): |
Jordi Palet Martinez jordi.palet[at]theipv6company.com The IPv6 Company |
Version: |
4.0 |
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Obsoletes: |
Amends: |
CPM art 3.1, 3.3, 3.4 and 3.6 |
1. Summary of the problem being addressed by this proposal
The Policy Development Working Group (PDWG) discusses about the policy proposals and anyone may participate either in the Resource Policy Discussion mailing list (RPD) and the bi-annual Public Policy Meetings (PPM).
However, there are several problems, accurate definitions and open questions that have been detected across the years:
- Consensus definition is not clear.
- Who constitutes the PDWG? Should participation be restricted to identified people?
- The PDP needs to work explicitly and without doubts of compliance in situations such as the Covid “new normal”.
- It is the discussion for the consensus (and possible appeals) only the one in the meeting, or it should explicitly be inclusive (allowing people that can’t be in meetings) stating that the mailings list is part of it.
- Shall the impact analysis be mandatory and what is the timing for that?
- The Last-Call is not well defined.
- Should the proposals expire if not updated and how often? Should appeals affect the timing? What about any Board delays for the ratification?
- Is the actual PDP timing good enough or should be improved?
- Can other on-line sessions be organized in addition to the formal Public Policy Meetings?
- Shall the functions of the board on the PDP matters be better described?
- Should the moderation of discussions process be explicit?
- Conflict resolution.
2. Summary of how this proposal addresses the problem
This proposal seeks to resolve all the issues stated above, and it has been designed having in mind that there are three other parts of the PDP that need to be adjusted in other proposals, in order to simplify reaching consensus in each part and in such way that each part can be adopted independently in case of lack of consensus in the others:
- PDWG Chairs eligibility, selections and roles. How the PDWG continue the work in case of absence/resignation/recall of one or both chairs?
- AUP (Acceptable Usage Policy) for the mailing list, do we need it or the AFRINIC CoC is sufficient and it is accepted by the community and who and how enforces it?
In some RIRs there is a mention in guidelines (not the PDP itself) about a moderation of discussion process, such as if a topic under discussion is old or out of timing, if an objection is minor or major, etc. However, the reality is that this is not being used in any RIR, neither in IETF, and we don’t see that this may improve the debates in the PDWG, and in fact will overcomplicate the management and create an unnecessary micro-management of the chairs. As a consequence, this proposal is not considering that the point “k” above, is a real problem that needs to be solved.
Proposal
3. Proposal
Amending 3.0 of the CPM, as follows:
| Current | Proposed |
|---|---|
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(doesn’t exist) |
3.1.1 Definition of “Rough Consensus” Achieving “rough consensus” does not mean that proposals are voted for and against, nor that the number of “yes’s”, “no’s” and “abstentions” – or even participants – are counted, but that the proposal has been discussed not only by its author(s) but also by other members of the community, regardless of their number, and that, after a period of discussion, all critical technical objections have been resolved. In general, this might coincide with a majority of members of the community in favor of the proposal, and with those who are against the proposal basing their objections on technical reasons as opposed to “subjective” reasons. In other words, low participation or participants who disagree for reasons that are not openly explained should not be considered a lack of consensus. Objections should not be measured by their number, but instead by their nature and quality within the context of a given proposal. For example, a member of the community whose opinion is against a proposal might receive many “emails” of support, yet the Chairs might consider that the opinion has already been addressed and technically refuted during the debate; in this case, the Chairs would ignore those expressions of support against the proposal. For information purposes, the definition of “consensus” used by the RIRs and the IETF is actually that of “rough consensus”, which allows better clarifying the goal in this context, given that “consensus” (Latin for agreement) might be interpreted as “agreed by al”’ (unanimity). More specifically, RFC7282, explains that “Rough consensus is achieved when all issues are addressed, but not necessarily accommodated.” Consequently, the use of “consensus” in the PDP, must be interpreted as “rough consensus”. |
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3.3 The Policy Development Working Group (PDWG) The Policy Development Working Group (PDWG) discusses about the proposals. Anyone may participate via the Internet or in person. PDWG work is carried out through the Resource Policy Discussion mailing list (rpd@afrinic.net) and the bi-annual AFRINIC Public Policy Meetings (PPM). Any person, participating either in person or remotely, is considered to be part of the Policy Development Working Group. |
3.3 The Policy Development Working Group (PDWG) The Policy Development Working Group (PDWG) is a forum open to the global community to discuss about Internet Number Resources policies and related topics applicable in the AFRINIC service region. Any real person may participate, either in person or using Internet (email, videoconferencing, etc.) and that means it is considered part of the PDWG. If necessary, taking into consideration the rights of Personal Data Protection, AFRINIC may formally verify the identity of the persons forming part of the PDWG. Typically, most of the work is carried out through the Resource Policy Discussion (RPD) mailing list (rpd@afrinic.net) and the AFRINIC Public Policy Meetings (PPM). Normally, 2 PPM will be held per calendar year, which might be on-line, in-person, or hybrid. If needed, more PPM could be held on-line only, in order to split the workload across the year, having shorter PPM sessions, facilitating the PDWG to concentrate in a smaller number of proposals. Other on-line sessions could be carried out in order to gather community inputs, or just as informative sessions, however those don’t count towards the consensus determination. |
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3.4.1 Draft Policy Proposal During the development of a policy, draft versions of the document are made available for review and comment by publishing them on the AFRINIC website and posting them to the rpd@afrinic.net mailing list. Each draft policy is assigned a unique identifier by AFRINIC and the AFRINIC website shall also contain the version history and the status of all proposals. The draft policy shall be available for review for at least four weeks before the next Public Policy Meeting. The author(s) shall make the necessary changes to the draft policy according to the feedback received. The Working Group Chair(s) may request AFRINIC to provide an analysis (technical, financial, legal or other), of the impact of the draft policy proposal. A draft policy expires after one calendar year unless it is approved by the AFRINIC Board of Directors as a policy. The timeout period is restarted when the draft policy is replaced by a more recent version of the proposal. A draft policy can be withdrawn by the author(s) by sending a notification to the Resource Policy Discussion mailing list. |
3.4.1 Policy Proposal and Discussion Timing During the development of a policy, versions of a policy proposal document are made available for discussion by publishing them on the AFRINIC website and posting them to the rpd@afrinic.net list. Each Policy Proposal Version (PPV) is assigned a unique identifier by AFRINIC and the AFRINIC website must also contain the version history and the status of all proposals and versions. For every PPV, AFRINIC must publish an Impact Analysis (IA) in a maximum of 4 weeks (from the submitted date) and at least 1 week before the PPM. When a complete IA is not possible within that timeframe, it should be duly justified in the RPD list and at least a draft version must be available. The PPV must be available for discussion for at least 2 weeks before the next PPM. The author(s) must make the necessary changes to the PPV according to the feedback received. A PPV expires after 6 months, unless it has been submitted by the Chairs for ratification by the AFRINIC Board of Directors as a policy. The timeout period is restarted when the PPV is replaced by a new version. A Policy Proposal can be withdrawn by the author(s) by sending a notification to the RPD List. An appeal pauses the 6-months expiry counter until the Appeal is resolved by the Appeal Committee (AC). Expired PPVs may be updated at a later stage, and will not be considered a new proposal, so they will keep the previous ID. Any PPV must be discussed on the RPD List a minimum of 8 weeks and maximum, the period of time required so it can be presented in the PPM. Consensus for a PPV can be determined only once it has been presented and discussed in the PPM. If a previous PPV has been already presented in a PPM, under request of the author(s), the Chairs could decide that a new presentation (at a PPM) is not needed if consensus could already be achieved in the RPD List when the changes have addressed previous objections. However, the 8 weeks discussion period in the RPD List is still required. |
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3.4.2 Public Policy Meeting The draft policy is placed on the agenda of an open public policy meeting. The agenda of the meeting shall be announced on the Resource Policy Discussion mailing list at least two weeks prior to the meeting. No change can be made to a draft policy within one week of the meeting. This is so that a stable version of the draft policy can be considered at the meeting. The Chair(s) determine(s) whether rough consensus has been achieved during the Public Policy Meeting. The Chair(s) shall publish the minutes of proceedings of the Public Policy Meeting not later than three weeks after the meeting. |
3.4.2 Public Policy Meeting and Consensus Determination Any new PPV must be placed on the agenda of a PPM. The agenda of the meeting must be announced on the RPD List at least 1 week prior to the meeting. No change can be made to a PPV within 1 week of the meeting. This is so that a stable version of the Policy Proposal can be considered at the meeting. Once the minimum 8 weeks of discussion in the list and a presentation at the PPM (for never presented Policy Proposals) are met, the Chairs have a maximum of 2 weeks to determine whether rough consensus has been achieved (considering both list and meeting). The Chairs must publish the minutes of proceedings of the PPM not later than 2 weeks after the meeting. For every PPV that doesn’t reach consensus, the Chairs should clearly state the reasons, in order for the authors to be able to work in an improved version. |
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3.4.3 Last Call A final review of the draft policy is initiated by the Working Group Chair(s) by sending an announcement to the Resource Policy Discussion mailing list. The Last Call period shall be at least two weeks. The Working Group Chair(s) shall evaluate the feedback received during the Public Policy Meeting during this period and decide whether consensus has been achieved. |
3.4.3 Last-Call A final discussion of the PPV is initiated by the Working Group Chairs by sending an announcement to the RPD List. The Last-Call period must be 2 weeks. Within 1 week after the end of the last-call, the Working Group Chairs must confirm whether consensus is maintained. The purpose of the “last-call” is to provide the community with a brief and final opportunity to comment on the PPV. Consequently, during this period pure editorial comments may be submitted and, exceptionally, objections if any aspect is discovered that was not considered in the discussion prior to determining consensus. Any new objections must also be substantiated and must therefore not be based on opinions lacking a technical justification. In case of editorial modifications, a new version must be published and the last-call period restarted. |
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3.4.4 Approval The Working Group Chair(s) shall recommend the draft policy to the AFRINIC Board of Directors for approval if it has the consensus of the Policy Development Working Group. The recommendation shall include a report of the discussions of the draft policy and feedback from the Last Call. The draft policy shall be ratified by the AFRINIC Board of Directors. |
3.4.4 Approval If consensus is declared, the Working Group Chairs will submit the Policy Proposal to the AFRINIC Board of Directors for ratification, include a short report of the discussions. The Board, as soon as possible after the report submission, must either:
The Board must communicate the decision to the PDWG. |
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(doesn’t exist) |
3.4.5 Additional Functions of the AFRINIC Board of Directors The community is the only responsible for the Policy Development, by means of the PDP. However, in exceptional emergency situations, duly justified, the Board may define temporary policy changes, which will only be valid until the next PPM. Those changes must be introduced as a Policy Proposal so they can be endorsed (or not) by the community. Attending to the exceptionality, the “Varying the Process” section could be used in order to speed up the process. In the event that such Policy Proposal doesn’t reach consensus, it will not be further enforced or implemented, however, any actions taken in terms of the policy up to the non-consensus determination, will remain valid. |
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3.5 Conflict Resolution A person who disagrees with the actions taken by the Chair(s) shall discuss the matter with the PDWG Chair(s) or with the PDWG. If the disagreement cannot be resolved in this way, the person may file an appeal with an Appeal Committee appointed by the AFRINIC Board of Directors. An appeal can only be filed if it is supported by three (3) persons from the Working Group who have participated in the discussions. The appeal must be submitted within two weeks of the public knowledge of the decision. The Appeal Committee shall issue a report on its review of the complaint to the Working Group. The Appeal Committee may direct that the Chair(s) decision be annulled if the Policy Development Process has not been followed. Anyone may request the recall of a Working Group Chair at any time, upon written request with justification to the AFRINIC Board of Directors. The request must be supported by at least five (5) other persons from the Working Group. The AFRINIC Board of Directors shall appoint a recall committee, excluding the persons requesting the recall and the Working Group Chairs. The recall committee shall investigate the circumstances of the justification for the recall and determine the outcome. |
3.5 Conflict Resolution A person who disagrees with the actions taken by the Chair(s) shall discuss the matter with the PDWG Chair(s) or with the PDWG. If the disagreement cannot be resolved in this way, the person may file an appeal with an AC, appointed by the AFRINIC Board of Directors. An appeal can only be filed if it is supported by three (3) persons from the Working Group who have participated in the discussions. The appeal must be submitted within two weeks of the public knowledge of the decision. The AC shall issue a report on its review of the complaint to the Working Group. The AC may direct that the Chair(s) decision be annulled if the Policy Development Process has not been followed. Anyone may request the recall of a Working Group Chair at any time, upon written request with justification to the AFRINIC Board of Directors. The request must be supported by at least five (5) other persons from the Working Group. The AFRINIC Board of Directors shall appoint a recall committee, excluding the persons requesting the recall and the Working Group Chairs. The recall committee shall investigate the circumstances of the justification for the recall and determine the outcome. Appeals and Recalls don’t modify the timing of the PDP. However, the Board must hold the ratification in case of an Appeal pending of resolution by the AC. |
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3.6 Varying the Process The process outlined in this document may vary in the case of an emergency. Variance is for use when a one-time waiving of some provision of this document is required.
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3.6 Varying the Process The timing outlined in this document may vary in the case of an emergency.
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5. References
A similar proposal reached consensus in LACNIC (May 2018), has been implemented and has been used already for several years. This version offers improved details considering the previous experience and the Covid-19 situation and other improvements introduced in the latest years to the LACNIC PDP.
Revision History
| Date | Details |
|---|---|
| 14/10/2026 |
Version 4: AFPUB-2026-GEN-005-DRAFT01 Further improvements. |
| 18/05/2022 |
Version 3: AFPUB-2021-GEN-002-DRAFT03 (archived) Updates related to the expiry of PPV. |
| 09/11/2021 |
Version 2: AFPUB-2021-GEN-002-DRAFT02 (archived) Changes to accommodate legal terminology as being misunderstood by the staff. Accommodated 3.6 to be shorter and avoid interpretation doubts. |
| 10/10/2021 |
Version 1: AFPUB-2021-GEN-002-DRAFT01 (archived) Initial Draft Posted to rpd |
AFRINIC Policy Impact Assessment
1. DPP Details
| Field | Details |
|---|---|
| Policy ID | AFPUB-2026-GEN-005-DRAFT01 |
| Policy Name | Update of PDP |
| URL of Policy Proposal | https://www.afrinic.net/afpub-2026-gen-005-draft01 |
| Affected CPM Section | CPM sections 3.1, 3.3, 3.4 and 3.6, as listed on the proposal page. The text also changes section 3.5 (Conflict Resolution). |
| Version of IA | v1 |
2. Previous Versions — Impact Assessments
| Version | Notes |
|---|---|
| v1 | Initial staff assessment for AFPUB-2026-GEN-005-DRAFT01. |
| Assessment basis | Current draft proposal text. |
3. Staff Interpretation and Understanding of the Proposal
This policy proposal modifies some aspects of the Policy Development Process (PDP) and introduces changes to the functioning of the Policy Development Working Group (PDWG).
The main changes are:
- The definition of rough consensus has been clarified to align with RFC 7282 (consensus is not a classic voting mechanism). In the PDP, “consensus” means “rough consensus”.
- Participants in the PDWG must be real people (AFRINIC may investigate, taking into consideration personal data protection rights).
- More than one PPM may be held per year to spread the workload (shorter PPMs are possible).
- For every PPV/version, AFRINIC must publish an Impact Analysis (IA) within a maximum of 4 weeks of the submission date and at least 1 week before the PPM. If a full IA cannot be ready in time, AFRINIC must give the reason on the RPD List and publish at least a draft.
- A PPV must be available for discussion at least 2 weeks before the next PPM (currently 4 weeks). It must also be discussed on the RPD List for at least 8 weeks before it is presented at the PPM (3.4.1).
- The author(s) must make the necessary changes to the PPV according to the feedback received.
- A PPV expires after 6 months (currently one calendar year), unless the Chairs have sent it to the Board for ratification. The 6-month count restarts when a new version replaces the PPV.
- An appeal pauses the 6-month expiry count until the appeal is resolved by the Appeal Committee (AC).
- An expired PPV can be updated later and keeps the same ID (3.4.1).
- Consensus can only be determined after the proposal has been presented and discussed at the PPM. If a PPV has already been presented at a PPM, the Chairs can decide that a new presentation at the next PPM is not needed if consensus can be reached on the RPD List because the changes have addressed previous objections. The 8-week discussion period still applies to the PPV (3.4.1). The author(s) may request that the PPV be presented at a PPM.
- Any new PPV must be placed on the agenda of a PPM.
- The PPM agenda is announced on the RPD List at least 1 week before the meeting (currently 2 weeks). No change can be made to a PPV in the last week before the meeting (3.4.2).
- The Chairs have up to 2 weeks to decide whether rough consensus has been reached, taking into account both the RPD List and the meeting. This means they no longer have to decide during the PPM, as they do today.
- The Chairs must publish the PPM minutes within 2 weeks (currently 3 weeks). When a PPV does not reach consensus, they must give the reasons (3.4.2).
- The Last-Call lasts exactly 2 weeks (currently at least 2 weeks). Within 1 week after the Last-Call ends, the Chairs must confirm whether consensus still exists. During the Last-Call, participants may only submit editorial comments. In exceptional cases, they may also submit objections, with supporting reasons, on points not previously discussed. An editorial change creates a new version and restarts the Last-Call (3.4.3).
- If the Chairs declare consensus, they send the PPV to the Board with a short report of the discussions. The Board must act as soon as possible. It may ratify the PPV after reviewing the implementation details and timing with staff, or it may return the PPV to the PDWG with its reasons and possible alternatives. The Board must inform the PDWG of its decision (3.4.4).
- In properly justified emergencies, the Board may make temporary policy changes. These changes remain valid only until the next PPM. They must be introduced as a policy proposal so that the community can support them, and the “Varying the Process” section can be used to speed up the process. If there is no consensus, the changes cease to apply, but actions already taken remain valid (new 3.4.5).
- Appeals and recalls do not change the timing of the PDP. However, the Board must not ratify a proposal while an appeal is open with the Appeal Committee (3.5).
- In an emergency, the Chairs may vary the process: 4 weeks of discussion and a 1-week Last-Call. If there is consensus, the policy is approved and must be presented at the next PPM (3.6). Currently, the review period, including the Last-Call, must be at least 4 weeks.
4. Staff Comments on Areas of Impact
4.1 AFRINIC Secretariat Duties
- There is no limit on the number of proposals that can be placed on a PPM agenda. Impact assessments are prepared in full and require input from internal teams.
- The proposal requires an IA for every PPV. For each version, the IA is due on the earlier of two dates: 4 weeks after submission, or 1 week before the PPM. If a version is submitted 3 weeks before the PPM, staff have 2 weeks. If it is submitted 2 weeks before, staff have 1 week. If it is submitted on the last permitted date (1 week before the PPM), the IA would be due on the same day; in that case, AFRINIC staff understand that a draft IA may be published. The text also does not state whether editorial versions published during the Last-Call (3.4.3) require a new IA, nor does it define what an IA must contain. The current PDP states that the analysis may be technical, financial, legal or other.
- The agenda must be announced 1 week before the PPM (currently 2 weeks), and the minutes must be published within 2 weeks (currently 3 weeks). These are duties of the Chairs. As the Secretariat supports the Chairs, the shorter periods increase the workload of both the Secretariat and the Chairs, especially if additional PPMs are held.
- The Secretariat would need to maintain the version history and status of every PPV. It would need to track the 6-month expiry count for each PPV, including pauses during appeals and restarts when a new version is published. It would also need to manage the reuse of IDs when an expired PPV is revived, and track restarts of the Last-Call. For this purpose, AFRINIC would need a PPV tracking tool supported by a published procedure.
- AFRINIC “may formally verify” the identity of PDWG participants “if necessary”. The proposal does not state when verification is necessary, who decides, what evidence is accepted, how personal data is handled, or what happens if a participant is not verified. AFRINIC would need a procedure and resources before applying this provision.
- Additional online-only PPMs may be held, with no limit on their number. Each one requires planning, an agenda announcement and Secretariat support, and each must also comply with the required discussion periods.
- The Board must ratify or return a proposal “as soon as possible” after the Chairs’ report, and must review implementation details and timing with staff. Unlike the Chairs, the Board has no fixed time limit. Staff should expect to be asked for an implementation assessment when the Board considers ratification.
4.2 Legal Assessment
- The proposal undoubtedly falls within the scope of section 3.1 of the PDP Manual, as it concerns amendments to the Policy Development Process itself. There is therefore no issue as to its admissibility for the purposes of Article 11.3 of the AFRINIC Bylaws.
- However, the proposed amendments raise certain legal and governance concerns that require further examination.
4.2.1 Definition of Rough Consensus
- The proposed definition states that rough consensus is achieved where all “critical technical objections have been resolved”. It further suggests that objections should be assessed by their “nature and quality” rather than their number, and that objections based on “subjective” reasons may be disregarded.
- Recognising that consensus is not a simple majority vote is consistent with established practice in the RIR community. As drafted, however, the proposal becomes problematic insofar as it appears to restrict the relevant objections to technical objections only. Policy proposals may also raise legitimate legal, financial, operational, governance or competition concerns, including those identified by AFRINIC staff in their impact assessments. It would therefore be useful to clarify whether, and how, such concerns are to be considered by the Chairs in determining consensus. In particular, the Chairs should not be precluded from considering substantive concerns merely because they are non-technical.
- The reference to a “majority” of the community is also potentially confusing when read alongside the assertion that participant numbers should not be counted. The author is advised to consider alternative wording to avoid any ambiguity in that respect.
4.2.2 Identity Verification and Personal Data
- There is no inherent legal objection to verifying identity where reasonably necessary to protect the integrity of the policy process. However:
- The proposal provides that AFRINIC “may” verify the identities of persons participating in the PDWG, subject to personal data protection rights. The use of “may” suggests that identity verification is discretionary rather than mandatory. If that is the intention, clarification is required as to who will authorise such verification and the circumstances in which it may be carried out, in order to avoid the exercise of unfettered discretionary powers.
- For the sake of certainty, the proposal should also clarify: the purposes for which such verification may be undertaken; whether it will apply to all participants, both existing and future; the categories of personal data that may be collected; the applicable retention period; and whether identity verification may affect participation in discussions or the determination of consensus. These clarifications will provide AFRINIC with the necessary lawful basis to collect and process the relevant personal data.
4.2.3 Mandatory Impact Assessment
- The requirement for a mandatory impact assessment is sound in principle, but the timeframes and the consequences of an incomplete assessment should be clarified. Otherwise, the provision could create legal uncertainty as to whether the policy development process has been validly followed. Such clarity is important to avoid unnecessary appeals.
4.2.4 Board Ratification
- With regard to the provision on Board ratification, section 129 of the Companies Act 2001 provides that the business and affairs of a company are managed by, or under the direction or supervision of, its Board, subject to the Act and the company’s Constitution. Similarly, section 143 imposes statutory duties on directors, including the duty to exercise their powers honestly, in good faith, in the best interests of the company, and for the purposes for which those powers were conferred.
- Accordingly, it is recommended that the proposal be worded so as not to create the impression that the AFRINIC Board is obliged to ratify a policy proposal where it identifies a legal impediment that cannot adequately be addressed by returning the proposal for further discussion. In other words, the provision should expressly preserve the Board’s ability to act in accordance with applicable law and its constitutional responsibilities, while requiring it to provide transparent reasons for its decision.
4.2.5 Board’s Temporary Policy
- With regard to proposed section 3.4.5, the author’s attention is drawn to Articles 11.4 and 11.5 of the AFRINIC Bylaws, and the author is invited to consider whether the proposed provision is needed.
4.2.6 General Observation: Risk of Concurrent and Overlapping Policy Proposals
- AFPUB-2026-GEN-001-DRAFT02 (PDP Working Group Guidelines and Procedures) and AFPUB-2026-GEN-005-DRAFT01 (Update of PDP) contain overlapping provisions that may conflict, as both proposals seek to amend aspects of the existing Policy Development Process, particularly the provisions governing the PDWG, its administration, appeals and the Board’s role in policy ratification.
- There is therefore a risk that the two proposals could be progressed independently, each on the basis of the existing policy framework, without adequately accounting for the amendments contemplated by the other. If consensus is reached on both, this could result in conflicting provisions.
- To avoid this, it would be advisable for the Chairs to give the authors an opportunity to coordinate their respective drafts, or otherwise to clarify how the proposed amendments are intended to operate together.
5. Staff Clarification Requests
- In Section 3.4.2, the author is requested to clarify whether discussions on the PPVs shall continue to be carried out during the 2 weeks after the PPM during which the PDWG Chairs will determine whether consensus has been reached.
- Appeals and timing: Paragraph 3.4.1 states that an appeal pauses the 6-month expiry count, whereas paragraph 3.5 states that appeals and recalls do not change the timing of the PDP. The author should clarify which time period(s) an appeal affects.
- Discussion periods: Paragraph 3.4.1 requires a PPV to be available “at least 2 weeks” before the PPM and also requires “a minimum of 8 weeks” of discussion on the RPD List. Moreover, as written, the 8-week period applies to “any PPV”, so each new version may require a further 8 weeks. The author should confirm whether this is the intention.