Dear Working Group,

I announced too many weeks ago that a small group was looking into the
IPv6 policy, as it is today, why it is what it is, and whether the
underlying assumptions that the policy is based on are still valid.

After taking way too long (apologies - lots of good excuses, but
this really shouldn't have dragged so long), I present you document
with a very personal view on the IPv6 address policy, coming from me,
Kurt Kayser and Sander Steffan (.txt and .pdf).

This is not a task force document, this is not a formal WG document,
and this is not an official RIPE document (though it might make a labs
article).  It is intended as a personal look at 24-odd years of IPv6 
policy...  and to spur discussion and further work on some areas 
that feel "in the rough".

We'll present about this next week, picking some points as starting
points for "shall we do something here?  if yes, what?  and who?" -
but this is not about *me*, but about the commounity - *you*.  Anyone 
is free and welcome to start a discussion and work on aspects we brought 
up - or on other aspects.

Gert Doering
        -- long-time IPv6 policy geek
-- 
have you enabled IPv6 on something today...?

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Preamble
At RIPE83, the new APWG chairs suggested an overhaul of the IPv6 address policy 
- both policy text and policy itself, if needed. Some WG members volunteered to 
look into the part “why is the current policy the way it is? Are the 
fundamental motivations still valid?”... and this is a starting document for 
further discussions in the WG.
This document is not a formal WG document, nor a product of a formal task 
force, but a personal view of the authors.
Authors
Gert Döring, Kurt Kayser, Sander Steffann
Scope
We have focussed exclusively on IPv6 policy. This does not mean that policies 
about other resources, such as ASNs, won’t benefit from a closer look. But 
that is out of scope for this document.
Underlying assumptions and motivations
The following underlying assumptions, goals and drivers went into the IPv6 
policy, as it is now - not commenting on the merits of either point here.  
Discussion follows, grouped in a somewhat topical way, in the next sessions.


* It should be easy to get IPv6 address space.
* RIPE IPv6 address policy should encourage IPv6 rollout, not get in the way.
* Aggregation is very important, both inside an ISP network and for the global 
routing system
* Conservation of IPv6 address space is a desirable criteria, but at the same 
time it is acknowledged that the IPv6 address space is very large, so 
allocation and assignments can be more liberal (“wastive”) than for IPv4
* Implementation of allocation and assignment policies should be easy, and 
require less paperwork and bureaucracy than for IPv4
* Use of N:1 NAT (ISPs assigning single IPv6 addresses to customers) is seen as 
undesirable
* “Special Networks” exist that need stable IPv6 addresses which must not 
be tied to any particular uplink provider - namely, Anycast root DNS servers 
and IXP exchange fabrics (some need to be seen in the global routing system, 
others just need to be unique)
* “Renumbering networks is hard”
* “Multihoming needs to be done with BGP”  (due to lack of widely accepted 
IETF alternatives)
* IETF failed to deliver on “new” multihoming solutions, so a certain - 
limited - number of companies exist that need address space not tied to a 
specific upstream provider, but can be announced over multiple providers or 
taken from upstream A to upstream B when changing contracts.
Evaluation
Looking into each of these - partially conflicting - goals and assumptions in 
more detail:
“Simplicity, encouragement, aggregation, discourage N:1 NAT”
The end result of forming policy for these goals is:
* ISPs can give end users a whole network block, up to a /48 per end site, 
without needing justifications (generally a /56 is recommended for SoHo end 
users, which is still 256 subnets of IETF-recommended size /64) - and most ISPs 
that provide IPv6 connectivity to end users seem to assign a /56, so the policy 
works.
* Unlike IPv4, end customers are not encouraged to use NAT to work around 
address shortage, and also do not need to come back regularly because they need 
more addresses due to network growth. 
* RIPE LIRs can get a /29 address block from the RIPE NCC without needing any 
justification, so receive sufficient address space for 0.5 Million /48 
assignments, or about 134 Million /56 assignments.  Less, if internal 
aggregation is needed, but still sufficient for all but the largest service 
providers.
* Most RIPE LIRs will not come back to the RIPE NCC to ask for more address 
space for a long time - or not at all.
* If a RIPE LIR needs more than a /29, the need for internal network 
aggregation is taken into account when judging allocation size based on number 
of /56s needed (numerically, the algorithm used is “HD ratio”)


Most general assumptions leading there are still valid and the existing IPv6 
policy seems to reasonably balance these needs.  Especially the “easy to 
operate, little bureaucracy, encourage IPv6 usage” part is still important.


Items under discussion:
* 2.7 Utilization & 2.8 HD-Ratio are seen as “too complicated”
   * the wording (“bits to the left of the efficiency measurement unit”) 
could be less scientific, and easier to understand
   * it does take into account that “larger networks with multiple levels of 
aggregations” can not be as efficient as “smaller networks”, so there is 
a mathematical justification for doing so, and not just asking for “10% 
utilization” - but are we overdoing it, for the common cases?
* 5.1.2 for “allocations larger than a /29”, and 5.2.1 “subsequent 
allocation criteria” - it is (sometimes) very hard to bring the necessary 
documentation
   * especially the bump “no documentation for /29” to “full 
documentation for /28” is steep(!).
   * Some cases are easy, like “traditional ISP networks”, where a LIR can 
just count customers, POPs, etc., and document their network aggregation 
hierarchy.
   * For other large networks, more situated in the enterprise or government 
arena, it is considered a huge effort to prepare this detailed level of 
documentation.
   * increasing the general allocation size (“a /24 for everybody”) would 
not solve the problem for very large networks, and needlessly use more address 
space for “smaller LIRs”
* 5.7 “Existing IPv6 address holders” is seen as contradicting 5.2.1 - does 
a LIR need to bring documentation for an extension of its address allocation, 
or not?  (Clarification in 5.7 that this refers to LIRs having been allocated a 
smaller-than-usual network, i.e. a /32 or /35, should help reducing the 
confusion)
* 4.2 Routability is not guaranteed, but there is little guidance on routing 
aggregation in the address policy (currently 3.4: “should be distributed in a 
hierarchical manner”) - this is a situation outside the direct responsibility 
of address policy, but if we could give advice here, or point to a BCOP 
document, this would be helpful for newcomers that are looking for guidance on 
commonly accepted levels of deaggregation, vs. what could be called “network 
vandalism”.
* Unbounded deaggregation of LIR PA blocks (/29s) into “more specifics 
announced by other entities” might create lots of demand for AS numbers as 
well.
* 4.4 “Consideration of IPv4 Infrastructure” - is this still a relevant 
criteria?  Does it create an unfair situation for “old networks that have 
lots of IPv4” vs. “new networks that have great plans, but no v4 to back 
their numbers”?  Is it just moot and should go?
“Special Networks”
The needs of IXP fabrics (unique, not tied to any particular ISP, possibly not 
even routed) and anycast root DNS servers (unique, tied to root DNS instance 
and not to any particular operator) have not changed.
With the general availability of IPv6 PI address space, it is unclear whether 
these special-case blocks are still needed or whether “plain” IPv6 PI could 
serve the needs.
“Renumbering, Multihoming, Provider-Independence”
For non-trivial networks, the whole aspects of “renumbering on ISP change” 
and also “multihoming to multiple different providers” still does not have 
good solutions in IETF.  Existing solutions are “use BGP routing and 
multihoming” - which has obvious scalability limitations in regards to the 
global routing table - or “use IPv6 NAT/Prefix translation” - which has 
implications on end-to-end address transparency.
Solving these is outside the RIPE APWG’s scope.
If we acknowledge that the requirements for “BGP based multihoming” for a 
certain subset of networks exist, the consequences are “owners of such 
networks need to have portable address space”.  With the current address 
policy, LIRs can use a PA /29 for that (splitting up the /29 among multiple 
independent locations, if needed), while non-LIR end users can receive IPv6 PI 
space, with a /48 per end site, non-aggregatable.
Some problems in this space are
* routing table size (global impact)
* yearly recurring costs for address space holders (IPv6 PI is cheaper than a 
full RIPE NCC membership)
   * discouraging IPv6 PI use conflicts with encouraging IPv6 deployment
* aggregability of multiple IPv6 PI assignments to PI holders that have 
multiple independent end sites (e.g. 5 sites = 5x /48, not 1x /45)
* IPv6 PI assignment to LIRs holding IPv6 PA is something the policy permits 
(7.2), but only by demonstrating a “unique routing requirement”, the 
interpretation of which can create quite a bit of friction between LIRs and the 
NCC registration services. 
Transfer Policy and Stockpiling
IPv6 address blocks can be transferred under the “normal” Transfer Policy 
(RIPE-682), just like IPv4 address blocks or AS numbers.
This is not something intrinsic to IPv6 needs, but came out of the desire to 
have a unified Transfer Policy for all number resources managed by the RIPE 
NCC.  That said, there are legitimate business cases for transfers of IPv6 
blocks, like mergers and acquisitions, and having identical policies for all 
resource types makes this much easier for all parties involved.
We have observed that some entities have acquired multiple /29s, in a few cases 
up to “over 50” /29s.  This is not exactly the intended outcome, but we 
consider this as not critical yet (50 /29s are about a /22 worth of total 
space, of which there are many).  The common assumption is that this is a side 
effect of certain actors opening multiple LIRs to collect multiple IPv4 /22 
address blocks, and then merging the LIRs with their v4 and v6 space - so the 
amount of /29s involved should become somewhat bounded.  Monitoring of future 
developments is still seen as necessary.
Recommendations: items where revisiting policy might be worth considering
(not calling this “Conclusions” as we want the work to start here, not to 
end)
* simplify language
* simplify requirements for /28, /27, /26 … allocations - explicit numbers, 
not HD ratio, and maybe start with “less drastic” documentation 
requirements for “just +1 bit”? 
* change default allocation size? (4.3)
* revisit “special case” assignments for IXP fabrics and root DNS operators 
(6.) <-> loosen up general IPv6 PI policy (for LIRs!) or keep special cases?
* possibly fold IPv6 for IXP policy into main IPv6 policy document 
(https://www.ripe.net/publications/docs/ripe-451)
* revisit IPv6 PI  (7.x)
   * cost
   * aggregability
   * multihoming options
   * criteria for assignment
* revisit aggregation requirements and expectations (BCOP)

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