[address-policy-wg] IPv6 Stockpiling

Hi Marco, All,

One reason for a LIR to have multiple /29 is when a lir (ISP in this case) buys smaller operators and consolidates them.
Since all of these blocks had some use before consolidation and its tedious to renumber....

I don’t see this as stockpiling, they will be even more in use in the future anyway, and we need to have enough use before being able to obtain more space...

Rgds,

Ray



For Internal Use Only

-----Original Message-----
From: address-policy-wg <address-policy-wg-bounces at ripe.net> On Behalf Of JORDI PALET MARTINEZ via address-policy-wg
Sent: perjantai 29. lokakuuta 2021 14.02
To: address-policy-wg at ripe.net
Subject: Re: [address-policy-wg] IPv6 Stockpiling

Hi Marco, all,

I think we need to better understand the reasons/background on those multiple allocations.

If the justification for a larger allocation is too "heavy" (I personally don't think so), we need to amend the language or the internal NCC procedure to facilitate larger allocations.

I can also understand that some "bad" actors are actually doing this for stockpiling, but I fail to see how they could take advantage of that even in the medium/long term. I don't think they will be able to make business out of those addressed in the next hundred years or even more ... because I can't see how exhaustion can happen earlier.

Definitively if they are trying to use this for other ISPs, it makes no sense, and it is bad for IPv6 deployment.

So again, I'm convinced that we need to better understand the reasons why this is happening before taking concrete actions, unless I'm missing something else.
 
Now, I've another question here. Once there are no more IPv4 addresses to give out ... there is any real business to allow "multiple LIRs" without a "stronger" justification? Because that will also resolve this problem ...

Regards,
Jordi
@jordipalet
 
 

El 29/10/21 12:03, "address-policy-wg en nombre de Marco Schmidt" <address-policy-wg-bounces at ripe.net en nombre de mschmidt at ripe.net> escribió:

    Dear colleagues,

    During RIPE 82, we provided you with an update on our observation of 
    IPv6 stockpiling [1]. Based on the feedback we received and in 
    preparation for the coming RIPE meeting, we would like to give you 
    another update on that issue.

    According to the IPv6 Address Allocation and Assignment Policy, an LIR 
    can receive up to a /29 IPv6 allocation without needing to supply any 
    additional information. The RIPE community considered this size 
    sufficient for most organisations for long-term IPv6 deployment. 
    Additionally, LIRs may qualify allocations greater than /29 by 
    submitting documentation that reasonably justifies this request [2].

    However, over the past few years we have noticed that some organisations 
    are collecting multiple IPv6 allocations in ways that are permitted by 
    current RIPE policies but might conflict with the above-mentioned intent 
    of the IPv6 policy. For example, it is possible for a single RIPE NCC 
    member to receive a /29 allocation for each of the multiple LIR accounts 
    that it holds. This is the result of a policy change in 2018 [3]. LIRs 
    can also receive multiple IPv6 allocations via policy transfers without 
    needing any further justification. However, when the IPv6 transfer 
    policy was discussed in 2014, it was assumed that there wouldn't be an 
    active transfer market [4].

    We have gathered data showing the significant development of the 
    collection of IPv6:
    - Almost 700 IPv6 allocations have been transferred in 2021 so far (and 
    there have been more than 3,900 transfers since policy implementation in 
    2015)
    - About 60% all IPv6 allocations ever handed out by the RIPE NCC are now 
    held as multiple allocations
    - In the last three months, more than 75% of all new allocations were 
    given to members that already hold at least one IPv6 allocation
    - More than 1,500 members hold multiple IPv6 allocations, exceeding the 
    size /29
    - Almost 100 members hold more than 10 IPv6 allocations (the maximum is 
    102 IPv6 allocations held by one member)

    It is the RIPE NCC’s understanding that some of these situations are 
    within the intent of previous policy changes, for example, to avoid 
    renumbering of deployed IPv6 networks during holdership changes, or if a 
    large company has multiple network departments that prefer to manage 
    their own allocation.
    However, the huge volume indicates that most are for other reasons. 
    While members can collect multiple IPv6 allocations without evaluation 
    by the RIPE NCC, we still were able to gather some feedback how members 
    plan to use their allocations. Many members simply stockpile them for an 
    undefined future use, others plan to use them for activities which 
    temporarily require a vast amount of IPs, and some plan to offer IPv6 on 
    a large scale to other ISPs in their country.

    We believe that this situation could create several issues:
    - IPv6 might be deployed in conflict with RIPE policies, underlying RFCs 
    and other best practices, resulting in challenges to that IPv6 
    deployment once the policy violation is discovered during an audit
    - There could be a negative impact on the quality of the registry if 
    large parts of allocations were given to third parties without clear 
    registration requirements
    - The policy requirement to justify larger IPv6 allocations would then 
    be rendered useless

    If you agree that this is a problem, we would like to initiate a 
    discussion in this Working Group about possible solutions. We see at 
    least two potential paths forward.

    Firstly, if the Working Group believes that this trend is an indication 
    of a widespread need for IPv6 address space larger than /29, then the 
    requirement for justification could perhaps be adjusted for a larger 
    allocation size. Members could then more easily get the address space 
    they need, but as an aggregated block. Stockpiling would still be 
    possible under this potential policy change, in fact on an even bigger 
    scale.

    Secondly, if the Working Group believes that this trend is in conflict 
    with the original intent of the IPv6 policy, adjustments to the policy 
    can be proposed that give the RIPE NCC a stronger mandate to enforce it. 
    One challenge here would be defining what IPv6 usages are considered 
    within or outside of the intent of the policy and how to ensure better 
    oversight without too much impact on IPv6 deployment.

    There might be other options that this working group can consider and 
    discuss.
    If required, the RIPE NCC can provide additional information for this 
    discussion.

    Kind regards,
    Marco Schmidt
    Registry Services Assistant Manager
    RIPE NCC

    [1] https://ripe82.ripe.net/presentations/7-RIPE82-Feeback-from-RS.pdf 
    from slide 9
    [2] https://www.ripe.net/publications/docs/ripe-738#initial_allocation
    [3] https://www.ripe.net/participate/policies/proposals/2018-01
    [4] https://www.ripe.net/participate/policies/proposals/2014-12





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