Dear SIG members,
Here is the Secretariat impact analysis for proposal “prop-164-v002:
Allocations of IPv6 Resources longer than a /32 with a nibble boundary
alignment” and the same is also published at:
https://www.apnic.net/community/policy/proposals/prop-164/
Regards
Dave Phelan
on Behalf of APNIC Secretariat
1. APNIC’s Understanding of the Proposed Policy
This Proposed Policy aims change the minimum allocation size of IPv6 prefixes
from /32 to /36. The proposer has indicated that this is to provide more
accurate data for sub-assignment of these resources.
Changes would be required to APNIC-127 if this proposal reaches consensus.
The Secretariat notes the following points:
The current policy text under '5.2.3.1 LIR-to-ISP allocation' mentions how LIRs
can sub-allocate IPv6 to their subordinate ISPs, suggesting IPv6
sub-allocations should be made to the LIRs downstream ISPs (who are connected
to them). The updated text does not reference the term 'subordinate ISPs'
Add a new line that reads: "When an LIR makes a delegation to an ISP”
This could be interpreted as LIRs can make sub-allocations to any ISPs
regardless if they are connected with that LIR or not.
Consideration needs to be made on the impact of existing allocations and
whether Resource Holders can “Return” the balance of their /32 so that they
only hold a /36, as the authors have not made it clear is this is a situation
they have considered.
The authors also need to consider consistency of language (ie:
allocation/assignment/delegation
Clarification would be required from the authors on the above 3 points prior to
editorial changes and call for comment.
2. Impact of Proposed Policy on Registry and Addressing System
As at 14th August 2025, there are 3095 Resource Holders that would potentially
qualify for this change.This may create an increased workload on the Member
services team in processing these requests as we would anticipate that the IPv6
Assignments would be returned in exchange for a /36 allocationWe don’t believe
that this will create further fragmentation in the global routing table. The
currently announced assignments would be replaced with the allocated address
space
3. Impact of Proposed Policy on APNIC Operation/Services
Changes would be required within APNIC systems to reduce the minimum allocation
size in front and back-end systems
4. Legal Impact of Proposed Policy
No Legal impact identified
5. Implementation
Changes in the policy text(APNIC-127) would need to be processed as per APNIC’s
Document Editorial Policy(APNIC-112)
There will be several systems changes required to core registry and resource
systems.
Implementation time frame would be 6 Months subject to the call for editorial
comments period.
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