------------------------------------------------------- prop-175-v001: Needs-Based Initial IPv6 PI Assignment ------------------------------------------------------- Proposer: Rafeeun Noby Babir rnbabir@gmail.com 1. Problem statement ------------------------------------------------------- APNIC-127 Section 9.1.4.1 currently states: "The initial IPv6 PI assignment to eligible applicants is /48." Section 9.1.4.2 separately states that requirements exceeding /48 are evaluated as subsequent IPv6 PI assignments under Section 9.2 of the APNIC IPv6 guidelines. APNIC-114 Section 9.2 already provides a needs-based assessment for IPv6 PI assignments larger than /48. It considers, among other things: - whether the network address plan demonstrates a need above the /48 threshold; - whether the network plan requires multiple discrete networks; - how the existing assignment is used with regard to routing announcements and aggregation; and - how additional address space would be managed to minimize growth of the global IPv6 routing table. This creates a distinction between the initial and subsequent request processes. An organization may know, before receiving its first PI assignment, that its planned network requires multiple discrete networks, which is one of the conditions on which APNIC-114 Section 9.2 already permits an assignment larger than /48. However, the current policy specifies a /48 as the initial PI assignment and provides the needs-based assessment for additional space only through the subsequent-assignment process. The applicant may therefore need to: 1. receive the initial /48; 2. proceed with its network deployment; 3. submit a subsequent request; 4. provide substantially the same network planning information again; and 5. undergo a second evaluation for address space that was already required and documented at the initial request. This creates additional administrative overhead for both the applicant and APNIC. It can also result in an avoidable second assignment where a single initial assignment based on the demonstrated requirement could have supported the documented deployment. APNIC-127 Section 3.1.7 (Minimized Overhead) states that overhead includes the need to return to the RIR for additional space too frequently, and that there is overhead associated with address space that grows through a number of small successive incremental expansions rather than through fewer, but larger, expansions. The situation described above is precisely that overhead. 2. Objective of policy change ------------------------------------------------------- The objective of this proposal is to allow the initial IPv6 PI request to be evaluated according to the applicant's demonstrated operational requirement when that requirement is already known at the time of the initial application. The proposal aims to: - avoid unnecessary subsequent requests; - reduce duplicate evaluation of the same planned deployment; - support efficient aggregation; - maintain needs-based resource management; and - provide consistent treatment of applicants whose requirements are known at the initial request. Throughout this proposal the qualifying condition is expressed using APNIC's existing policy term, multiple discrete networks, as used in APNIC-114 Section 9.2. Points of Presence, campuses, data centres and geographically distributed infrastructure are referred to only as examples of deployments that may give rise to that condition. They are not introduced as new policy criteria. Throughout this proposal, the assignment size is expressed as being based on the demonstrated requirement, assessed under APNIC's existing conservation, aggregation, and routing-table minimisation principles. The proposal does not use a separate standard of appropriateness. 3. Situation in other regions ------------------------------------------------------- ARIN provides, in current policy (NRPM 2025.1, Section 6.5.8.2), a needs-based mechanism for determining larger initial IPv6 end-user assignments. Organizations meeting the initial assignment criteria are eligible for a /48, and requests for larger initial assignments, reasonably justified with supporting documentation, are evaluated on the number of sites in the organization's network. RIPE NCC's current policy provides for PI assignments larger than /48 where the need is justified. RIPE NCC policy proposal 2024-01, which is a proposal and not current policy, has further considered the operational overhead associated with repeated PI requests and the routing implications of that overhead. Other RIRs also provide mechanisms for assignments beyond the general /48 case, although their eligibility and assessment mechanisms differ. These approaches demonstrate that assessing IPv6 assignment size according to documented operational requirements is an established policy approach in other RIR communities. This proposal does not seek to replicate their specific prefix-size thresholds or mechanisms. 4. Proposed policy solution ------------------------------------------------------- 5.1 Initial versus subsequent assessment The purpose of this proposal is not to create a separate needs-assessment framework for initial PI assignments. The existing subsequent-assignment framework already provides a mechanism for evaluating demonstrated requirements above /48. The proposed change allows that assessment to be applied at the initial request when the applicant can provide the required information before receiving the first assignment. This avoids making the timing of the requirement, before or after the first assignment, the determining factor in whether the applicant must submit a second request. Three amendments are proposed. The first, to APNIC-127 Section 9.1.4.1, allows the assessment to occur at the initial request. The second, to APNIC-114 Section 9.2, makes the existing criteria capable of being applied to an applicant that does not yet hold a PI assignment. The third, to APNIC-114 Section 9.1.4, brings the guideline into line with the amended policy. 5.2 Amendment to APNIC-127 Section 9.1.4.1 Current policy APNIC-127 Section 9.1.4.1 states: "The initial IPv6 PI assignment to eligible applicants is /48." Proposed policy Replace Section 9.1.4.1 with: 9.1.4.1 Initial assignment The minimum initial IPv6 PI assignment to eligible applicants is /48. Where an applicant demonstrates, at the time of the initial request, a requirement for IPv6 PI address space exceeding /48, APNIC shall evaluate the request using the applicable needs-based criteria specified in Section 9.2 of the APNIC guidelines for IPv6 allocation and assignment requests. Where the demonstrated requirement is justified, APNIC may approve an initial IPv6 PI assignment larger than /48. The assignment size shall be based on the demonstrated requirement and shall be consistent with the existing APNIC principles of conservation, aggregation, fairness, and minimization of global routing-table growth. The applicant must demonstrate that the assigned address space will be used for the intended purpose and will comply with the existing requirements for IPv6 PI assignments. 5.3 Amendment to APNIC-114 Section 9.2 APNIC-114 Section 9.2 provides the criteria under which an address block larger than /48 may be assigned. One of those criteria requires the organization to demonstrate its use of the previous assignment. That criterion cannot be satisfied by an applicant that does not yet hold a PI assignment. Without a corresponding amendment, Section 9.2 could not be applied to an initial request. Section 9.2 also requires the applicant to demonstrate how the subsequent assignment would be managed to minimise the growth of the global IPv6 routing table. For an initial request there is no subsequent assignment, so that criterion must be read as applying to the proposed initial assignment. Add the following to APNIC-114 Section 9.2: For an initial IPv6 PI assignment requested under Section 9.1.4.1 of the APNIC Internet Number Resource Policies, the requirement to demonstrate the use of a previous assignment does not apply. For an initial request, the requirement concerning management of a subsequent assignment shall be interpreted as applying to the proposed initial assignment. The applicant shall demonstrate that the proposed assignment will be managed to minimise global routing announcements and maximise aggregation, and to minimise growth of the global IPv6 routing table. The other criteria in Section 9.2 remain unchanged. 5.4 Amendment to APNIC-114 Section 9.1.4 APNIC-114 Section 9.1.4 describes the initial IPv6 PI assignment as a /48. If APNIC-127 Section 9.1.4.1 is amended as proposed above, the guideline would otherwise continue to state a fixed /48. This is a consequential amendment only. Replace the sentence describing the initial IPv6 PI assignment as /48 with: The minimum initial IPv6 PI assignment is /48. Where the applicant demonstrates a requirement exceeding /48 at the time of the initial request, the request shall be evaluated under Section 9.2. All other eligibility and operational requirements in APNIC-114 Section 9.1.4 remain unchanged, including those concerning use, announcement, monitoring and reclamation. This proposal does not modify who is eligible to apply for an IPv6 PI assignment. 5. Advantages / Disadvantages ------------------------------------------------------- Advantages: 16.1 Reduces unnecessary subsequent requests Applicants do not need to receive /48 first and subsequently request additional space when the requirement was already known. 16.2 Uses an existing assessment framework APNIC does not need to create a new needs-assessment methodology. The existing IPv6 PI subsequent-assignment criteria provide the basis for the initial assessment. 16.3 Preserves /48 as the normal minimum Organizations requiring only a /48 remain unaffected. 16.4 Supports aggregation A single assignment based on the demonstrated requirement can reduce the need for multiple independent assignments and associated route announcements. 16.5 Maintains conservation Additional address space remains subject to demonstrated need. 16.6 Improves policy clarity The policy explicitly distinguishes between: - the minimum initial assignment; and - an initial assignment that is larger because a documented requirement is already demonstrated. 16.7 Reduces administrative overhead The same requirement does not need to be evaluated twice merely because the applicant identified it before deployment. Disadvantages: Applicants requesting more than /48 will need to provide sufficient documentation to justify the requirement during the initial request. APNIC Hostmasters may therefore need to perform a more detailed evaluation for some initial requests. However, this evaluation uses the existing needs-based framework and may eliminate the need for a later subsequent-assignment request. 6. Impact on resource holders ------------------------------------------------------- The expected implementation impact is limited. APNIC may need to: - update the wording of APNIC-114; - update IPv6 PI request forms; - update Hostmaster guidance; - update relevant public documentation. No new resource category is created. No new eligibility category is created. No change to IPv6 transfer policy is proposed. APNIC-127 Section 9.1.4 provides that the first /48 PI assignment to Associate Members is excluded from the annual fee calculation. This proposal does not propose any change to the APNIC Member Fee Schedule. Any fee implications arising from an initial assignment larger than /48 should be addressed through the existing fee framework. 7. References ------------------------------------------------------- [1] APNIC-127: APNIC Internet Number Resource Policies, version 015, 20 February 2025. Section 3.1.3 (Aggregation), Section 3.1.5 (Conservation), Section 3.1.6 (Fairness), Section 3.1.7 (Minimized Overhead), Section 3.2.8 (Reservations not supported), Section 4.1.2 (Validity of delegations), Section 5.6 (General requirements for requests), Section 8 (IPv6 allocations), Section 9.1 (Criteria for IPv6 Assignments), Section 9.1.1 (IPv6 for multihoming), Section 9.1.2 (IPv6 critical infrastructure), Section 9.1.3 (IPv6 for Internet Exchange Points), Section 9.1.4 (Provider Independent IPv6 assignment), Section 9.1.4.1 (Initial assignment), Section 9.1.4.2 (Subsequent assignment), Section 13 (IPv6 Transfers), Appendix A (HD-Ratio). https://www.apnic.net/community/policy/resources [2] APNIC-114: APNIC guidelines for IPv6 allocation and assignment requests, version 012, 7 May 2024. Section 9.1 (Initial assignments), Section 9.1.4 (Provider Independent assignment), Section 9.2 (Subsequent assignments). https://www.apnic.net/about-apnic/corporate-documents/documents/ resource-guidelines/ipv6-guidelines/ [3] APNIC Policy Development Process. https://www.apnic.net/community/policy/process/ [4] prop-160: Change IPv6 Initial assignment to /44 for Organizations Eligible for multihoming. https://www.apnic.net/community/policy/proposals/prop-160/ [5] prop-164: Allocations of IPv6 Resources longer than a /32 with a nibble boundary alignment. https://www.apnic.net/community/policy/proposals/prop-164/ [6] ARIN Number Resource Policy Manual, version 2025.1, 3 March 2026. Section 6.5.8.2 (Initial Assignment Size). https://www.arin.net/participate/policy/nrpm/ [7] RIPE NCC policy proposal 2024-01: Revised IPv6 PI Assignment Policy. https://www.ripe.net/community/policies/proposals/2024-01/ [8] ripe-738: IPv6 Address Allocation and Assignment Policy, Section 7 (Provider Independent (PI) Assignments for End Users). https://www.ripe.net/publications/docs/ripe-738/ [9] LACNIC Policy Manual (IPv6 assignments to end users). https://www.lacnic.net/1057/2/lacnic/ [10] AFRINIC Policy Manual, IPv6 Address Allocation and Assignment Policy. https://afrinic.net/policy/manual [11] RFC 6177: IPv6 Address Assignment to End Sites. https://www.rfc-editor.org/rfc/rfc6177