[address-policy-wg] ALLOCATED FINAL and M&As

This suggestion is intended to address the problem of abusively opening
many LIRs or many companies to make new members to stockpile addresses
from the last /8.

First, if there are intended to be special rules applying to these
addresses, they should have a special status to make it clear. For the
sake of argument ALLOCATED FINAL. This doesn't change anything, it just
makes things a bit more explicit.

Any organisation should be entitled to at most one such FINAL allocation
from RIPE (if we go back to multiple LIR accounts, only one of them may
get a FINAL block). FINAL allocations are only for use on the Internet,
not for internal, non-announced uses: that is a legitimate use case, but
don't squander the last of the pool for that.

Transfers of FINAL blocks are only allowed if they are demonstrably in
use. "In use" means (1) announced in the global BGP tables and (2) with
documentation of deployment in a non-trivial topology, i.e. assigning
everything in the /22 to a single host so that it answers ICMP packets
doesn't fly.

Yes, there are still ways to game this, but the bar is much higher. Yes,
it means that the NCC has to do more work to check that transfers are
legitimate, but that is a necessary cost for dealing with the problem of
the bad actors.

---

Motivation/disclosure.

HUBS is made up of a dozen or so small rural providers mostly in the
south of Scotland. We are an LIR and allocate addresses to them on
pretty much the same basis as we get them from RIPE. We encourage them
to do IPv6 but made an explicit choice not to dictate or interfere in
their internal operations. They may use their IPv4 allocations for
"CG"-NAT, or assign them to customers, and we offer advice but not more.

Another organisation, WHAN, was set up to do this along similar lines on
the west coast (and actually to extend the model by making a distributed
IXP for their networks to connect to rather than looking like a transit
provider). There is some overlap of people (exactly two) but they
operate in a different geographical area and the set of member networks 
is completely disjoint.

At some point it is quite possible that these two organistions will
merge. That would be extremely and unnecessarily painful if that meant
that networks already assigned and in use had to be returned. These 
organisations are already operating in areas characterised by market
failure, on extremely tight budgets largely reliant on volunteers to
provide the only option for decent Internet access. The policy that has
been mooted of a rigid rule of exactly one final allocation per
organisation would be hugely damaging.

Best wishes,

William Waites
Network Engineer
HUBS AS60241