[address-policy-wg] IPv6 Stockpiling

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