Dear colleagues,

I very much support the direction of the proposal, and I would like to thank 
Tobias and Clara for their persistence. 

Reading the impact analysis, it strikes me that there are two different 
categories of concern raised by the NCC:

Implementation cost:

Software, processes, documentation and training/exam material would need to be 
changed. If "We would have to change things and that costs money" becomes a 
sufficient argument against a proposed policy change we might as well stop 
doing them. Nothing in this line of reasoning tells me anything about the 
substance of the proposal, and the merits of it. 

I am also somewhat disappointed that the Executive board thought it fitting to 
advise revision in a single sentence without any stated reasoning - and I'm not 
going to dig through the board minutes to find the reasoning, if it exists. I 
would very much like to hear the board's reasoning; both for the comment itself 
and the way they decided to present it.

Actual substance:

There are I think 3 findings that this proposal will need to address before we 
can proceed.

1 - Transition mathematics. Existing /48 assignments sit in /46 reservations. 
The entire installed base is therefore impossible to extend in place to 'the 
next nibble' or a /44. With that, grow in place becomes a mandatory 
renumber-and-return exercise for everyone who wants additional space.

2 - The transfer gap. The return obligation only applies to the previous 
assignment - the new block can immediately be (partly) transferred. This 
creates the exact fragmentation this proposal seeks to avoid. 

3 - Internal consistency.  Proposed 2.6 permits conditional sub-assignment and 
the untouched text of article 7 still states that PI cannot be further 
sub-assigned, and the interaction with 7.2 would put an End User who later 
becomes a member/LIR themselves in automatic violation. 

On the NCC's enforcement dilemma: this is the permanent shape of every 
needs-based policy we've ever had, going back all the way to the original IPv4 
policy. The same goes for the ambiguity of the term 'end site': I see that that 
will become a policy proposal in its own right and I'm very much looking 
forward to reading it - it is overdue by decades, in my opinion. 

Neither of these problems is introduced by this proposal, and I don't see why 
these arguments should be used as an implementation blocker.

To summarise: I support the intent, but we should find language that addresses 
my points above. Those are the actual substance, not the training courses.

Kind regards

Remco

> On 25 Aug 2026, at 14:56, Angela Dall'Ara <[email protected]> wrote:
> 
> 
> 
> Dear colleagues,
> 
> 
> 
> Policy proposal 2024-01, "Revised IPv6 PI Assignment Policy", is now in the 
> Review Phase.
> 
> 
> 
> The RIPE NCC has prepared an impact analysis on this proposal to support the 
> community’s discussion.
> 
> 
> 
> You can find the proposal and impact analysis at:
> 
> https://www.ripe.net/community/policies/proposals/2024-01/
> https://www.ripe.net/community/policies/proposals/2024-01/#impact-analysis
> And the draft document at:
> 
> https://www.ripe.net/community/policies/proposals/2024-01/draft/
> 
> 
> As per the RIPE Policy Development Process (PDP), the purpose of this 
> four-week Review Phase is to continue the discussion of the proposal taking 
> the impact analysis into consideration, and to review the full draft RIPE 
> Policy Document.
> 
> 
> 
> At the end of the Review Phase, the Working Group (WG) Chairs will determine 
> whether the WG has reached rough consensus.
> 
> 
> It is therefore important to provide your opinion, even if it is simply a 
> restatement of your input from the previous phase.
> 
> 
> 
> We encourage you to read the proposal, impact analysis and draft document and 
> to send any comments to [email protected] before 23 September 2026.
> 
> 
> Kind regards, 
> Angela Dall'Ara
> Policy Officer
> RIPE NCC
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