I agree this proposal just kicks the can down the road and I would like to see the underlying issues fixed.  I think we're all in agreement on that.

For the list record, I'll briefly summarise my personal experience over the last few years of requesting more/larger IPv6 allocations:

  1.  New LIR with a greenfield network build.  Zero customers, but the business plan/forecast would have us exceeding the initial allocation very quickly if we followed RIPE-690 and used /48-sized prefix delegation.
  2. Two LIRs both owned by the same legal entity. LIR1 had exhausted its initial /29 allocation, and requested expansion or another allocation, the NCC said "Why aren't you using the /29 in LIR2?" and told us to transfer the unused /29 from LIR2 to LIR1.
  3. LIR2 now wants to start deploying IPv6 so requests a new initial allocation because it no longer has one.  The NCC says "You've already had your initial allocation, you can't have anymore".

Issue 1, is a bit of a chicken and egg deal, and policy could probably be updated to improve this specific situation, if the community thinks it should. (But I concede this is a unique case)
Issues 2 and 3 are more misunderstandings or perhaps misinterpretations.  I don't think policy changes are required to change the fundamentals, but perhaps the wording of the policy could be updated to avoid the misinterpretations.  e.g., defining "Member" == "LIR", not "Account Holder", and clarifying or renaming "Initial Allocation".


From: Tore Anderson <tore@fud.no>
Date: Friday, 7 November 2025 at 09:46
To: Nick Hilliard <nick@foobar.org>, jordi.palet@consulintel.es <jordi.palet@consulintel.es>
Cc: RIPE Address Policy Working Group <address-policy-wg@ripe.net>
Subject: [EXTERNAL] [address-policy-wg] Re: 2024-02 New Version Policy Proposal (IPv6 Initial Allocations /28 and extension to /28)

Den 06.11.2025 19:06, skreiv Nick Hilliard:
> If we tweak the netmask one bit to the left, from /29 to /28, then all
> that will happen is that we'll be talking about 1m customers instead
> of 1/2m, but the underlying problem will still be there, and unsolved.
>
> That is why we need to discuss and try to fix the underlying problem.

The above succinctly summarises my thoughts about this policy proposal.
It seems to just kick the can down the road.

Is it truly the case the an LIRs with >500k active subscribers all ready
to be assigned /48s will *not* receive an initial allocation of a /28,
if they request one? I see this argument is being made, but I have a
hard time believing it, if I am being honest. I do not understand how
the NCC could possibly refuse such a request based on section 5.1.2 in
the policy.

Tore

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