Multiple Editorial Changes in IPv6 Policy

Summary of Proposal:

This proposal suggests multiple editorial changes to the IPv6 Policy. The intent is to remove unnecessary text and simplify the policy.

There are multiple paragraphs in the IPv6 Policy that refer to “lack of experience” or “potential new changes” – things that are now obsolete, or clearly no longer the case.

Section 5.4.2 states that the policy was drafted at a time when there was no experience with IPv6 deployment, which is no longer the case. It is does not make sense to have the RIPE NCC evaluate whether the end sites of an LIR’s End User require a shorter prefix than a /48.

Section 5.4.1 is reworded to mention a RIPE BCOP and 5.4.3 is deleted, as it is clear that operators need to assign some space for different parts of their own infrastructure.

Finally, Section 7 is reworded, taking advantage of editorial changes in the preceding sections, to avoid redundancy.

Policy Text:

a) Current Policy text (ripe-707)

1.1 Overview

[...]

This policy is subject to future review and potential revision, subject to continuing experience in the administration of IPv6.

[...]

2.9. End Site

An End Site is defined as an End User (subscriber) who has a business or legal relationship (same or associated entities) with a service provider that involves:

• that service provider assigning address space to the End User
• that service provider providing transit service for the End User to other sites
• that service provider carrying the End User's traffic
• that service provider advertising an aggregate prefix route that contains the End User's assignment

5.4. Assignment

LIRs must make IPv6 assignments in accordance with the following provisions.

5.4.1. Assignment address space size

End Users are assigned an End Site assignment from their LIR or ISP. The size of the assignment is a local decision for the LIR or ISP to make, using a minimum value of a /64 (only one subnet is anticipated for the End Site).

5.4.2. Assignments shorter than a /48 to a single End Site

When a single End Site requires an assignment shorter than a /48, it must request the assignment with documentation or materials that justify the request. Requests for multiple or additional prefixes exceeding a /48 assignment for a single End Site will be processed and reviewed (i.e., evaluation of justification) at the RIR/NIR level.

Note: There is no experience at the present time with the assignment of multiple network prefixes to the same End Site. Having the RIR review all such assignments is intended to be a temporary measure until some experience has been gained and some common policies can be developed. In addition, additional work at defining policies in this space will likely be carried out in the near future.

5.4.3. Assignment to operator's infrastructure

An LIR may assign a network prefix per PoP as the service infrastructure of an IPv6 service operator. Each assignment to a PoP is regarded as one assignment regardless of the number of users using the PoP. A separate assignment can be obtained for the in-house operations of the operator.

[...]

7. IPv6 Provider Independent (PI) Assignments

To qualify for IPv6 PI address space, an organisation must meet the requirements of the policies described in the RIPE NCC document entitled “Contractual Requirements for Provider Independent Resources Holders in the RIPE NCC Service Region”.

The RIPE NCC will assign the prefix directly to the End User organisations upon a request properly submitted to the RIPE NCC, either directly or through a sponsoring LIR.

The minimum size of the assignment is a /48. Organisations requesting a larger assignment (shorter prefix) must provide documentation justifying the need for additional subnets.

Additional assignments may also be made when the need is demonstrated and documented based on address usage, or because different routing requirements exist for additional assignments. When possible, these further assignments will be made from an adjacent address block.

Assignments will be made from a separate 'designated block' to facilitate filtering practices.

The PI assignment cannot be further sub-assigned to other organisations.

7.1 IPv6 Provider Independent (PI) Assignments for LIRs

LIRs can qualify for an IPv6 PI assignment for parts of their own infrastructure that are not used for customer end sites. Where an LIR has an IPv6 allocation, the LIR must demonstrate the unique routing requirements for the PI assignment.

The LIR should return the IPv6 PI assignment within a period of six months if the original criteria on which the assignment was based are no longer valid.

[...]

b) New Policy Text

1.1 Overview

[...]

(text removed)

[...]

2.9. End Site

An End Site is defined as the location of an End User (subscriber) who has a business or legal relationship (same or associated entities) with a service provider that involves:

• that service provider assigning address space to the End User location
• that service provider providing transit service for the End User location to other sites
• that service provider carrying the End User's location traffic
• that service provider advertising an aggregate prefix route that contains the End User's location assignment

5.4. Assignment

LIRs must make IPv6 assignments in accordance with the following provisions.

5.4.1. Assignment address space size

End Users are assigned an End Site assignment from their LIR or ISP. The size of the assignment is a local decision for the LIR or ISP to make, using a value of "n" x /64. Section 4.2 of ripe-690 provides guidelines about this.

5.4.2. Assignments shorter than a /48 to a single End Site

Assignments larger than a /48 (shorter prefix) or additional assignments exceeding a total of a /48 must be based on address usage or because different routing requirements exist for additional assignments.

In case of an audit or when making a request for a subsequent allocation, the LIR must be able to present documentation justifying the need for assignments shorter than a /48 to a single End-Site.

[...]

7. IPv6 Provider Independent (PI) Assignments

To qualify for IPv6 PI address space, an organisation must meet the requirements of the policies described in the RIPE NCC document entitled “Contractual Requirements for Provider Independent Resources Holders in the RIPE NCC Service Region”.

The RIPE NCC will assign the prefix to the End User organisations upon a request properly submitted to the RIPE NCC, either directly or through a sponsoring LIR.

Assignments will be made from a separate “designated block” to facilitate filtering practices.

The PI assignment cannot be further sub-assigned to other organisations.

7.1 IPv6 Provider Independent (PI) Assignment Size

The minimum size of the assignment is a /48.

The considerations of "5.4.2. Assignments shorter than a /48 to a single End-Site" must be followed if needed.

7.2 IPv6 Provider Independent (PI) Assignments for LIRs

LIRs can qualify for an IPv6 PI assignment for parts of their own infrastructure that are not used for customer end sites. Where an LIR has an IPv6 allocation, the LIR must demonstrate the unique routing requirements for the PI assignment.

The LIR should return the IPv6 PI assignment within a period of six months if the original criteria on which the assignment was based are no longer valid.

[...]

Rationale:

a. Arguments Supporting the Proposal

This proposal supports a regular update of the policy backed up by IPv6 deployment experience, reducing the RIPE NCC’s overhead. 

b. Arguments Opposing the Proposal

LIRs could abuse this policy to justify a larger need for IPv6 space.

Counter argument: The Assisted Registry Check (ARC) process (additional allocations) will reveal these cases.

c. Situation in other RIRs

APNIC policy had this requirement
https://www.apnic.net/community/policy/resources#5.2.4.3.-Assignment-of-multiple-/48s-to-a-single-end-site, however an equivalent policy has reached consensus in the last meeting.

AFRINIC and LACNIC do not have this requirement in their IPv6 policies and recommend an assignment size of a /48
https://www.afrinic.net/policy/manual#Allocations-Assignments-Policies (section 6.5.4.1 Assignment address space size)
https://www.lacnic.net/684/2/lacnic/ (section 4.5.3.1 - Assignment address space size)

ARIN policy requires for larger initial assignments to be reasonably justified with supporting documentation, based on the number of sites in an organisation’s network and the number of subnets needed to support any extra-large sites.
https://www.arin.net/participate/policy/nrpm/#6-5-4-reassignments-from-lirs-isps

A. RIPE NCC's Understanding of the Proposed Policy

It is the RIPE NCC's understanding that this proposal recommends multiple editorial changes to the IPv6 Policy with the intent of removing unnecessary text and simplifying the policy.

The main difference is that the LIRs will no longer need to submit a request to the RIPE NCC to create IPv6 end site assignments larger than /48. The LIR will, however, need to justify such assignments should there be a RIPE NCC audit or when making a subsequent allocation request.

This proposal also clarifies the definition of ‘end site’, making it clear that it refers to the location of an end user. This is in line with current RIPE NCC procedures. An end user can request one /48 IPv6 assignment for each of its locations as long as they can provide proof of the location based on the conditions outlined the policy.

Further, the proposed policy change includes improved guidance for providers on how to decide the size of IPv6 assignments.

B. Impact of Policy on Registry and Addressing System

After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

C. Impact of Policy on RIPE NCC Operations/Services

No significant or immediate impact is expected on the workload of Registration Services if this proposal reaches consensus

D. Legal Impact of Policy

There is no significant legal impact expected if this policy reaches consensus.

E. Implementation

The RIPE NCC estimates that the implementation of this proposal would not have any significant impact. The IPv6 End Site Assignment request form will be decommissioned. Internal and external documentation would also need to be updated.