INTERNAL

I strongly agree with Nicks splitting of this into two separate parts, and his 
other comments.

Best regards,

Ian Dickinson
Chief Network Architect | Vitrifi Limited

-----Original Message-----
From: Nick Hilliard <[email protected]>
Sent: 13 May 2025 12:32
To: Angela Dall'Ara <[email protected]>
Cc: RIPE Address Policy Working Group <[email protected]>
Subject: [address-policy-wg] Re: 2024-02 Review Phase (IPv6 Initial Allocations 
/28)

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Angela Dall'Ara wrote on 13/05/2025 09:38:
> The RIPE NCC has prepared an impact analysis on this proposal to
> support the community's discussion.

Angela,

thanks for organising the impact analysis for this policy proposal.

tl;dr: I disagree with each of the two aspects of the proposal, and as a 
separate issue, the two should not appear in the same policy proposal together 
because they're independent of each other.

Jordi, Rinse,

There are two things in this proposal. On the one hand, it increases the size 
of initial allocations from /29 to /28. On the other hand, it proposes to 
change the terms of assignment so that the allocation limit applies to the RIPE 
NCC member rather than to the LIR, the idea being that this would help to 
prevent stop stockpiling of ipv6 address space.

 From a high level point of view, these two things are substantially different 
and independent to each other. The first is a technical solution to a technical 
problem, i.e. how to deal with organisations which might need more ipv6 address 
space, and on the face of it, this is a relatively straightforward change. The 
second is a subtle but fundamental policy shift about how address allocation 
works. The details and some of the consequences are outlined in the EB input 
section of the Impact Analysis, which categorises the change as both 
high-impact and high-risk from both a governance and policy management point of 
view.

In terms of the content of the changes:

Increase in Initial Allocation Size
--

There are currently 22731 ipv6 allocations, according to today's alloclist.txt 
file, which can be found in in ftp.ripe.net:/ripe/stats/membership/. Of these, 
68 are larger than /29, and there's only been a single allocation larger than 
/29 issued since Jan 1 2020. This suggests that the current initial allocation 
size is adequate to deal with most new requests for ipv6 address space. If you 
have alternative data which indicates otherwise, then it would be good to 
discuss this.

If organisations need more address space on day 1 but don't qualify for more 
than /29 (and there are some organisations who genuinely fall into this 
category), then the appropriate way to deal with this would be to change the 
Initial allocation policy in ripe-738, section 5.1.

It's not viable to justify a policy by stating "this proposal would resolve 
possible extension needs for the majority (91%) of members using the same 
prefix, just by extending some bits to the left". If there's a need for 
established LIRs to increase from /29 to /28, then you need to provide data to 
directly justify the change, rather than just stating that the proposal might 
resolve someone's possible needs.

The breakdown of allocation sizes from today's alloclist.txt is as follows:

/19 - 2
/20 - 2
/21 - 4
/22 - 4
/23 - 7
/24 - 7
/25 - 7
/26 - 10
/27 - 14
/28 - 11
/29 - 16406
/30 - 149
/31 - 79
/32 - 6029

It would help clarify future policy proposals / proposal revisions / APWG 
presentations if you could highlight the fact that currently less than 0.3% of 
current allocations are larger than /29. I.e. that the proposed change would 
benefit very few LIRs.

Application of Policy to Member rather than LIR
--

There are already anti-stockpiling processes in place:

> https://www/.
> ripe.net%2Fabout-us%2Fnews%2Fupdated-approach-to-ipv6-transfer-request
> s%2F&data=05%7C02%7Cian.dickinson%40vitrifi.net%7Cb0a652f5ba7945c53483
> 08dd9211e038%7Ce5df709ad9594deebc6442c4f223b0f4%7C0%7C0%7C638827327683
> 813587%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDA
> wMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sda
> ta=MEgpqouDUIXc0OWg4KkTEsAHMG5MHHI%2FR5bP0uRxry4%3D&reserved=0

If you want to change the ipv6 allocation policy to apply to per-member rather 
than per-LIR, it would be best to handle this in a separate policy, as the 
executive board has identified that there are significant downstream 
consequences of this part of the proposal. The new proposal should include the 
EB analysis of this proposal as the starting point for the "Arguments Opposing 
the Proposal" section.

Summary
--

1. the available data doesn't provide justification for the first change. If 
there's a problem with the Initial allocation policy or Subsequent allocations, 
then these aspects of the policy should be fixed rather than making a 
wide-ranging change which affects 100% of LIRs in order to deal with a problem 
which impacts significantly less than 1% of LIRs. In any event, data should be 
provided which adequately justifies the proposal.

2. applying allocation policy to members rather than LIRs is more complex than 
the proposal anticipated. There is currently very little discussion in the 
proposal to justify this change, and there are other controls in place to deal 
with the problem that it proposes to fix.

3. at best, it confuses the two changes to include both this and the change in 
allocation size in the same proposal: they are very different changes and act 
independently to the other.

Nick
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