80% Rule Ambiguity Cleanup

This proposal is to solve the ambiguity in the current wording of the IPv4 Allocation Policy (ripe-492) regarding the "80% utilisation" rule.

Summary of Proposal:

This proposal is to solve the ambiguity in the current wording of the IPv4 Allocation Policy (ripe-492) regarding the "80% utilisation" rule.

Policy Text:

Current:

Section 5.4:

The RIPE NCC considers sub-allocated space as “used” when evaluating requests from the LIR for an additional IPv4 allocation. LIRs are still required to demonstrate about 80% usage for all their allocations.

New (deleting the second sentence from current text):

Section 5.4:

The RIPE NCC considers sub-allocated space as “used” when evaluating requests from the LIR for an additional IPv4 allocation.

Rationale:

a. Arguments supporting the proposal

The current policy text of the IPv4 Allocation policy mentions "80%" both in section 5.3 and section 5.4, and due to the ambiguity in the wording, the two sections can be interpreted in different ways when an LIR with multiple existing allocations requests a new allocation from the RIPE NCC.

This proposed change will eliminate this ambiguity by removing the reference to the "80% rule" in the context of sub-allocations. The author of this proposal is also the author of the problematic text in section 5.4, and explicitly states that this text was never meant to change the interpretation of section 5.3, but only to emphasize that the "80% rule" stays still effective when sub-allocations are made from an allocation. Accordingly, it is better to remove the ambiguous sentence completely.

The ambiguity problem was brought up at RIPE 59, was discussed on the address policy mailing list after that (early 2010), and was again brought up at the RIPE 60 meeting. Feedback from the community was to go forward with the proposed change (and, implicitly, the interpretation that "section 5.3" is the way that the policy should be).

b. Arguments Opposing the Proposal

There have been statements that the whole concept of the "80% rule" should be reconsidered. This proposal does not try to do or prevent any work in that direction. It is just to clarify the existing rules.

Impact Analysis

Note: In order to provide additional information related to the proposal, details of an impact analysis carried out by the RIPE NCC are documented below. The projections presented in this analysis are based on existing data and should be viewed only as an indication of the possible impact that the policy might have if the proposal is accepted and implemented.

A. RIPE NCC's Understanding of the Proposed Policy

The RIPE NCC understands that this policy clarifies the policy text to clearly state what was decided during RIPE60. There it was made clear that the policy should be interpreted in such a way that an LIR is eligible to receive an additional allocation when a minimum of 80% of its total address space has been assigned.

B. Impact of Policy on Registry and Addressing System

Address/Internet Number Resource Consumption:
After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

Fragmentation/Aggregation:
After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

C. Impact of Policy on RIPE NCC Operations/Services

Registration Services:
After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

Billing/Finance Department:
After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

RIPE Database:
After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

D. Legal Impact of Policy

After analysing the data that is currently available, the RIPE NCC does not anticipate that the implementation of this proposed policy will cause any significant legal implications.