[address-policy-wg] Stockpiling IPv6 Update

Dear Address Policy Working Group,

During the last Address Policy WG session in October 2020, we provided an
update on the topic of stockpiling IPv6 allocations. For the upcoming
RIPE 82 meeting, we want to share some additional information to
support the community discussion.

To summarise, the RIPE NCC observed a significant amount of members
requesting several IPv6 allocations via multiple LIR accounts or the
transfer policy. Based on the IPv6 policy, it is possible to request up 
to a
/29 IPv6 allocation per LIR account, without any justification needed.

Firstly, we want to stress again that this is not about any potential
scarcity of IPv6. Rather we would like to ask the Working Group if the
current development is within the intend of the IPv6 policy.

Currently, we see around 100 members that have collected multiple IPv6
allocations with totaling amounts of /26 or more, with the maximum of 91 
IPv6
allocations (totals /23+).
To put this in perspective, in the last ten years, only 12 members could
document the need for initial allocations of a /26 or more, with a
decreasing trend in the last years while at the same time, more multiple
smaller IPv6 allocations are being requested.
We see a big discrepancy between organisations being able to justify
larger IPv6 allocation based on actual network plans (despite eased
policy requirements) and organisations that collect many /29 allocations
without any real requirement of justification.

We also noticed that some of the members rent out large blocks of their
multiple allocations to other ISPs. While the IPv6 policy supports this
approach, we would like to raise awareness that this creates a
strong dependency of the ISP to their LIR, especially if large IPv6
networks are being deployed. In case the members decide to change their
business model or terminate the membership, the sub-ordinated ISPs will
be forced to renumber whole IPv6 networks or follow any requirement set
by the LIR.

We hope that this information will help the Working Group to review if
the current development is in line with the intent of the IPv6 policy.

Kind regards,

Marco Schmidt
Assistant Manager Registry Services and Policy Development
RIPE NCC