This suggestion is intended to address the problem of abusively opening many LIRs or many companies to make new members to stockpile addresses from the last /8.
First, if there are intended to be special rules applying to these addresses, they should have a special status to make it clear. For the sake of argument ALLOCATED FINAL. This doesn't change anything, it just makes things a bit more explicit. Any organisation should be entitled to at most one such FINAL allocation from RIPE (if we go back to multiple LIR accounts, only one of them may get a FINAL block). FINAL allocations are only for use on the Internet, not for internal, non-announced uses: that is a legitimate use case, but don't squander the last of the pool for that. Transfers of FINAL blocks are only allowed if they are demonstrably in use. "In use" means (1) announced in the global BGP tables and (2) with documentation of deployment in a non-trivial topology, i.e. assigning everything in the /22 to a single host so that it answers ICMP packets doesn't fly. Yes, there are still ways to game this, but the bar is much higher. Yes, it means that the NCC has to do more work to check that transfers are legitimate, but that is a necessary cost for dealing with the problem of the bad actors. --- Motivation/disclosure. HUBS is made up of a dozen or so small rural providers mostly in the south of Scotland. We are an LIR and allocate addresses to them on pretty much the same basis as we get them from RIPE. We encourage them to do IPv6 but made an explicit choice not to dictate or interfere in their internal operations. They may use their IPv4 allocations for "CG"-NAT, or assign them to customers, and we offer advice but not more. Another organisation, WHAN, was set up to do this along similar lines on the west coast (and actually to extend the model by making a distributed IXP for their networks to connect to rather than looking like a transit provider). There is some overlap of people (exactly two) but they operate in a different geographical area and the set of member networks is completely disjoint. At some point it is quite possible that these two organistions will merge. That would be extremely and unnecessarily painful if that meant that networks already assigned and in use had to be returned. These organisations are already operating in areas characterised by market failure, on extremely tight budgets largely reliant on volunteers to provide the only option for decent Internet access. The policy that has been mooted of a rigid rule of exactly one final allocation per organisation would be hugely damaging. Best wishes, William Waites Network Engineer HUBS AS60241
