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
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Marco Schmidt