Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
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This appears to be a process error. A discussion has been started within the IETF to consider whether the proposal here is correct, but since the proposal here is actually not part of an IETF process, it could be that a conclusion will be drawn here that doesn't actually involve consultation with the IETF.
Given that the address space here is reserved for a different purpose by the IETF, this is not something ICANN should be doing. So I think the right thing to do here is to stop this process and liaise with the IETF to figure out how to proceed. Using the IPv4 prefix for this is probably not the right approach, but that's a discussion that should occur in the IETF, not here.
I urge ICANN to formally engage with the IETF to come up with a solution to this problem.