Assessment Criteria for IPv6 Initial Allocation Size

Summary of proposal

The current RIPE IPv6 Address Allocation and Assignment Policy (ripe-641, section 5.1.2) recognises only ‘the number of existing users and the extent of the organisation’s infrastructure’ when assessing the requirement for an initial allocation size greater than /29. This is proving problematic for organisations whose IPv6 addressing requirements are not fully represented by such criteria.

For example:

Hierarchical Networks – The infrastructure of some organisations, particularly those with a multi-national presence, is often made up of component networks which can be regarded as Internet service providers in their own right. In many cases these ISPs could be eligible to become LIRs themselves and therefore each could obtain a /29 without justification. However, it is often important that they operate subordinately to the ‘parent’ organisation not only administratively but also technically on matters such as routing and addressing. In such cases, the need for a hierarchical addressing strategy can lead to an overall addressing requirement larger than that measured simply by the number of End User networks yet the current assessment criteria does not allow consideration of this, despite the principles of hierarchy and aggregation being stated (in section 3) as key goals of address space management.

Multiple Discrete Networks – Some organisations have a requirement to operate multiple discrete networks with completely independent routing and address management policies. Justification varies but may include, for example, regulatory restrictions on data transmission or geographic distance/diversity between networks. However, the requirement for multiple discrete prefixes is not eligible for consideration by the current initial allocation size assessment criteria.

It is proposed that the assessment criteria for an initial allocation size greater than /29 should allow consideration of aspects other than ‘size’ alone. To achieve this, it is suggested that the specific criteria ‘number of existing users and the extent of the organisation’s infrastructure’ is removed from the sizing assessment and, optionally, replaced by specific exclusions if/as deemed necessary by the RIPE community.

Policy text:

[The following text will update section 5.1.2 in the RIPE Policy Document “IPv6 Address Allocation and Assignment Policy“, if the proposal reaches consensus.]

a. Current policy text

5.1.2. Initial allocation size

Organisations that meet the initial allocation criteria are eligible to receive an initial allocation of /32. For allocations up to /29 no additional documentation is necessary.

Organisations may qualify for an initial allocation greater than /29 by submitting documentation that reasonably justifies the request. If so, the allocation size will be based on the number of existing users and the extent of the organisation's infrastructure.

b. New policy text

5.1.2. Initial allocation size

Organisations that meet the initial allocation criteria are eligible to receive an initial allocation of /32. For allocations up to /29 no additional documentation is necessary.

Organisations may qualify for an initial allocation greater than /29 by submitting documentation that reasonably justifies the request. [Text removed]

Rationale:

The assessment criteria ‘number of End Users’ is arguably unambiguous and serves as one reasonable measure of the ‘size’ of an organisation. However, the term ‘extent of the organisation’s infrastructure’ is somewhat ambiguous and therefore open to interpretation. Even taking a dictionary definition of the term ‘extent’ to mean area, volume, scope, etc it is clear that again it is very much a measurement of ‘size’.

For many organisations (ISPs in particular) there is often a straightforward correlation between their ‘size’ and the amount of IPv6 address space they therefore require. However, many organisations have legitimate addressing requirements that arise from factors other than outright size alone and yet the current policy, as written, does not allow consideration of such requirements to be made.

a. Arguments supporting the proposal

• The proposal to remove the consideration of only ‘size’ when assessing an organisation’s eligibility for an initial allocation greater than /29 will better align the policy with the justified addressing requirements of a greater number of organisations. In doing so, this will not only satisfy the needs of those organisations but also provide benefit to the wider Internet community as a result of greater adoption and promotion of IPv6.
  
  
• The current policy may force organisations with justified hierarchical requirements to make smaller End User assignments in an attempt to fit within a restricted initial allocation size.
  
  
• The current policy may force organisations with legally independent subordinate ISPs to arrange for them to register as LIRs in order for them to obtain up to a /29 allocation each. Such allocations will inevitably be fragmented and non-aggregatable therefore potentially leading to unnecessary growth of the global routing table.
  
  
• The current policy may force organisations with global presence to ‘registry shop’ and obtain an initial allocation from another RIR whose allocation policy is less restrictive. Any benefit to the organisation could come at a cost to the underlying principles and benefits of regional allocation and management of the IPv6 address space.

b. Arguments against the proposal

• Removal of specific assessment criteria on which to base eligibility for, and sizing of, allocations greater than /29 could make it more difficult for the RIPE NCC’s IP Resource Analysts to assess individual requests and/or lead to inconsistency of policy application.
  
  Mitigation/counter-argument:
  RIPE NCC, through their impact analysis, can indicate their understanding of the proposal, how they would apply it and whether they believe any such difficulties could arise. This analysis, together with community input and refinement of the policy if/where appropriate, should ensure that a common understanding of the intent and application of policy is able to be reached.
  
  
• Removal of specific assessment criteria on which to base eligibility for, and sizing of, allocations greater than /29 could lead to abuse and/or waste of address space.
  
  Mitigation/counter-argument:
  In response to the fact that it is, in part, the specificity of the current policy that has led to the current problem situation it is proposed that an exhaustive list of allowable criteria is not (re)introduced. Instead, to mitigate the risk of abuse and/or wasteful practices, specific approaches/concepts (proposed and agreed by the RIPE community) could be explicitly excluded from being eligible for consideration.