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I'm wondering how we can proceed from here. Is it just a matter of confirming the actual situation with the RIRs, or do we need another process to confirm the interpretation?
Personally I would suggest that it may be worth an effort to formally amend the policy and specifically include criteria for access to IPv6 address blocks from the RIR or NIR as a PI allocation without a need for announcement for such blocks on the global Internet (which is what I infer from your description of a 'closed' network) regards, Geoff