Dear Colleagues,

I am Satoru Tsurumaki from Japan Open Policy Forum Steering Team.

I would like to share key feedback from our community regarding prop-170,
based on a meeting we organized on 24th Aug to discuss these proposals.
Please note that this is a summary of the discussions among the 17 Japanese
community members who attended the meeting.

Overall, participants expressed mostly negative opinions toward this
proposal.

(Comment details)

- Participants questioned whether there is sufficient operational demand
for nibble-boundary allocations to justify changing the policy.
- The proposal would result in significantly larger allocations than
actually requested in many cases. Participants felt that stronger
justification is needed for such additional address consumption.
- Some participants considered that existing sparse allocation practices
already provide sufficient flexibility for future expansion.
- Several participants felt that improved readability alone is not a
sufficient reason to justify allocating substantially larger address blocks.

Regards,

Satoru Tsurumaki
Japan Open Policy Forum Steering Team

2026年7月25日(土) 14:08 Shaila Sharmin <[email protected]>:

> Dear SIG members,
>
>
>
> A new proposal "prop-170: Nibble-Boundary Alignment for IPv6 Allocations"
>
> has been sent to the Policy SIG for review.
>
>
>
> It will be presented at the Open Policy Meeting (OPM) at APNIC 62 on
> Thursday, 10 September 2026.
>
>
>
> https://conference.apnic.net/62/program/program/index.html#/day/7/
>
>
>
> We invite you to review and comment on the proposal on the mailing list
> before the OPM.
>
>
>
> The comment period on the mailing list before the OPM is an important part
> of the Policy Development Process (PDP).
>
> We encourage you to express your views on the proposal:
>
>
>
> Do you support or oppose this proposal?
>
>
>
> Does this proposal solve a problem you are experiencing? If so,
>
> tell the community about your situation.
>
>
>
> Do you see any disadvantages in this proposal?
>
>
>
> Is there anything in the proposal that is not clear?
>
>
>
> What changes could be made to this proposal to make it more effective?
>
>
>
> Information about this proposal is appended below as well as available at:
>
>
>
>
>
> https://www.apnic.net/community/policy/proposals/prop-170/
>
>
>
> Regards,
>
> Bikram, Shaila, and Ching-Heng
>
> APNIC Policy SIG Chairs
>
>
>
>
>
>
>
> ------------------------------------------------------------------------
>
> prop-170-v001: Nibble-Boundary Alignment for IPv6 Allocations
>
> ------------------------------------------------------------------------
>
>
>
>
>
> Proposer:        Haisheng Yu*
>
>                  [email protected]*
>
>                  [email protected]
>
>
>
>
>
> Joint proposer:  Haijun Li
>
>                  [email protected]
>
>
>
>
>
> 1. Problem statement*
>
> --------------------
>
>
>
> The APNIC Internet Number Resource Policies establish the rules for IPv6
> allocations and assignments in the Asia Pacific region. Section 8 governs
> IPv6 allocations. Section 8.1 establishes a minimum IPv6 allocation size of
> /32 and allows a larger initial allocation where comprehensive
> documentation supports a larger calculated address requirement. Section
> 8.3.4 provides that an eligible account holder may receive a subsequent
> allocation that doubles the address space allocated to it and, where
> possible, expands the existing allocation using adjacent address space.
>
>
>
> The current policy does not establish a general principle for aligning
> IPv6 allocations to hexadecimal nibble boundaries. A nibble boundary is a
> prefix length evenly divisible by four, such as /20, /24, /28, or /32.
> Because IPv6 addresses are expressed in hexadecimal notation and each
> hexadecimal character represents four bits, nibble-boundary aligned blocks
> are generally easier to read, document, subdivide, automate, audit, and
> incorporate into long-term IPv6 address plans.
>
>
>
> Under the current policy, valid allocation outcomes may include prefixes
> such as /21, /23, /27, /29, /30, or /31. These prefixes are technically
> valid and can be routed, registered, and used. However, repeated one-bit
> expansions, or allocations based only on a non-aligned calculated
> requirement, may produce address plans that require additional operational
> handling in IP address management systems, customer addressing structures,
> routing templates, security segmentation records, audit systems, and future
> expansion planning.
>
>
>
> APNIC already uses a Sparse Allocation Framework to improve the
> possibility of contiguous growth. However, Section 8 does not currently
> provide a clear policy basis for nibble-boundary alignment where an LIR
> explicitly requests alignment and supports the request with a long-term
> IPv6 address plan.
>
>
>
> This proposal introduces a conditional nibble-boundary alignment mechanism
> for IPv6 allocations under Section 8. It applies to larger initial
> allocations and to subsequent allocations where the applicable eligibility
> and needs-based requirements have been met. It does not amend any IPv6
> assignment policy under Section 9.
>
>
>
> Nibble-boundary alignment does not replace APNIC's existing needs-based
> assessment. This proposal does not change:
>
>
>
>     - the /32 minimum IPv6 allocation size;
>
>     - the HD-Ratio utilization requirements;
>
>     - the one-bit doubling mechanism as the default mechanism for
> subsequent allocations;
>
>     - the eligibility and documentation requirements for larger
> allocations;
>
>     - APNIC's Sparse Allocation Framework;
>
>     - the treatment of multiple discrete networks; or
>
>     - any IPv6 assignment policy under Section 9.
>
>
>
> Existing resource holders will not be required to renumber, return, or
> resize any previously delegated IPv6 prefix.
>
>
>
>
>
> 2. Objective of policy change
>
> -----------------------------
>
>
>
> The objective of this proposal is to introduce a clear and conditional
> nibble-boundary alignment mechanism for LIR IPv6 allocations under Section
> 8, while preserving APNIC's existing needs-based review, resource
> stewardship, and operational flexibility.
>
>
>
> Under the proposed policy:
>
>
>
>     - Section 8.0 will define a nibble boundary, define the supporting
> long-term IPv6 address plan, and clarify the scope of the proposal;
>
>     - Section 8.1 will provide that, where an applicant explicitly
> requests nibble-boundary alignment and supports the request with a
> long-term IPv6 address plan, APNIC will normally delegate the smallest
> nibble-boundary aligned block that can satisfy the calculated address
> requirement;
>
>     - Section 8.3.4 will retain one-bit doubling as the default subsequent
> allocation size;
>
>     - an account holder requesting a subsequent allocation larger than the
> default doubling must continue to justify the new requirement under the
> existing needs-based criteria;
>
>     - after the larger requirement has been validated, where possible, the
> existing allocation will be expanded so that the resulting aggregate is
> nibble-boundary aligned and sufficient to satisfy the validated requirement;
>
>     - if the existing allocation cannot be expanded, or cannot be expanded
> adequately, APNIC may make a separate allocation of the size justified, on
> a nibble boundary where operationally practicable;
>
>     - nibble-boundary alignment will not be an unconditional entitlement;
> and
>
>     - Sections 8.2.1, 8.2.2, and all of Section 9 will remain unchanged.
>
>
>
>
>
> 3. Situation in other regions
>
> -----------------------------
>
>
>
> ARIN Number Resource Policy Manual (NRPM), Section 6, provides the
> clearest existing RIR policy example for nibble-boundary IPv6 allocation
> and assignment.
>
>
>
> Key original wording from ARIN includes:
>
>
>
>     - Section 6.5.1 defines a nibble boundary as a "network mask which
> aligns on a 4-bit boundary".
>
>     - Section 6.5.2.1 states: "All allocations shall be made on nibble
> boundaries."
>
>     - Section 6.5.8.3 uses the concept of "one or more justified nibble
> boundaries" for subsequent end-user assignments.
>
>
>
> The relevant ARIN policy structure is broader than a single definition.
> Section 6.3.4 identifies aggregation as an IPv6 address management goal and
> explains that IPv6 policy should avoid fragmentation of address ranges.
> Section 6.3.7 addresses the need to reduce administrative overhead and
> avoid repeated small incremental requests. Section 6.3.8 states that
> aggregation is the most important IPv6 address policy goal.
>
>
>
> ARIN's policy demonstrates that nibble-boundary allocation can coexist
> with needs-based review. It does not operate as uncontrolled
> over-allocation. Instead, it combines a clear definition, needs-based
> eligibility, controls for large allocation sizes, contiguous expansion
> where possible, and operational flexibility for special network structures.
>
>
>
> The current RIPE IPv6 policy, RIPE-738, does not establish a general
> mandatory nibble-boundary rule for LIR allocations equivalent to ARIN's.
> However, its top-level policy objectives are closely aligned with the
> operational rationale of this proposal and provide policy-level support for
> the same direction: aggregation, avoidance of fragmentation, and reduced
> administrative overhead.
>
>
>
> Key original wording from RIPE-738 includes:
>
>
>
>     - Section 2.7 identifies minimizing overhead as a policy goal,
> including minimizing "overhead associated with obtaining address space".
>
>     - Section 3.4 states that IPv6 address space should be distributed in
> a hierarchical manner "to permit the aggregation of routing information"
> and that aggregation is the "highest priority" in IPv6 address policy.
>
>
>
> RIPE Policy Proposal 2024-01 is not current RIPE policy and does not
> revise LIR PA allocation rules. It concerns IPv6 Provider Independent
> assignments for end users. Although the scope is different, the proposal's
> core operational logic is relevant: nibble-boundary sizing can reduce
> repeated incremental requests, avoid network-wide renumbering, and trade a
> modest short-term increase in delegated address space for longer-term
> operational stability.
>
>
>
> This proposal is distinct from APNIC prop-164. It does not reduce the
> minimum IPv6 allocation from /32, does not establish /36 as the new minimum
> allocation, and does not require existing resource holders to return
> address space. Prop-164 addressed whether smaller initial IPv6 allocations
> should be available under APNIC policy. This proposal instead adds a
> conditional nibble-boundary planning rule for Section 8 LIR IPv6
> allocations while preserving APNIC's existing needs-based review framework.
>
>
>
>
>
> 4. Proposed policy solution
>
> ---------------------------
>
>
>
> This proposal makes three policy text changes:
>
>
>
>     - add definitions and scope under Section 8.0;
>
>     - add a conditional alignment paragraph under Section 8.1; and
>
>     - add a conditional alignment mechanism under Section 8.3.4.
>
>
>
>
>
> 4.1 Add definitions and scope under Section 8.0
>
>
>
> Insert the following text immediately after the heading "8.0 IPv6
> allocations":
>
>
>
>     Nibble-boundary alignment
>
>
>
>     A nibble boundary is a prefix length evenly divisible by four.
>
>
>
>     For the purposes of Sections 8.1 and 8.3.4, a long-term IPv6 address
> plan is documentation supporting the requested allocation size. It may
> include, as applicable, expected user, customer, or site growth; the extent
> of the infrastructure; hierarchical and geographical network structure;
> security segmentation; and the planned longevity of the allocation.
>
>
>
>     Nibble-boundary alignment applies only where an applicant explicitly
> requests it and provides the supporting long-term IPv6 address plan
> required by the applicable section.
>
>
>
>     Nibble-boundary alignment does not replace or reduce any eligibility,
> utilization, HD-Ratio, or documentation requirement. It does not create an
> unconditional entitlement to additional address space.
>
>
>
>     These provisions apply only to IPv6 allocations under Section 8. They
> do not amend any IPv6 assignment policy under Section 9.
>
>
>
>
>
> 4.2 Amend Section 8.1 Minimum IPv6 allocation
>
>
>
> Retain the existing text of Section 8.1 and add the following paragraph
> after its existing final paragraph:
>
>
>
>     Where an applicant explicitly requests nibble-boundary alignment and
> provides a long-term IPv6 address plan, APNIC will normally delegate the
> smallest nibble-boundary aligned block that can satisfy the calculated
> address requirement.
>
>
>
>     This provision applies only after the address requirement has been
> assessed in accordance with this section. It does not replace the HD-Ratio
> based utilization policy or any supporting-documentation requirement.
>
>
>
> Section 8.1 establishes the /32 minimum allocation size and governs the
> sizing of larger initial allocations.
>
>
>
> The expression "the smallest nibble-boundary aligned block that can
> satisfy the calculated address requirement" means the least amount of
> nibble-boundary aligned address space capable of meeting the requirement
> calculated under the existing policy. The alignment mechanism does not
> independently establish or enlarge the underlying requirement.
>
>
>
> If nibble-boundary alignment is not requested, the initial allocation will
> continue to be processed under the existing Section 8.1 and Section 8.2
> rules.
>
>
>
>
>
> 4.3 Amend Section 8.3.4 Size of subsequent allocation
>
>
>
> Retain the existing text of Section 8.3.4:
>
>
>
>     When an account holder has achieved an acceptable utilization for its
> allocated address space, it is immediately eligible to obtain an additional
> allocation that results in a doubling of the address space allocated to it.
>
>
>
>     Where possible, except where separate disaggregated ranges are
> requested for multiple discrete networks, the allocation will be made from
> an adjacent address block, meaning that its existing allocation is extended
> by one bit to the left.
>
>
>
>     If an account holder needs more address space, it must provide
> documentation justifying its new requirements. The allocation size will be
> based on the new needs (the number of users, the extent of the
> infrastructure, the hierarchical and geographical structuring of the
> account holder's operations, the segmentation of infrastructure for
> security and the planned longevity of the allocation).
>
>
>
> Add the following text at the end of Section 8.3.4:
>
>
>
>     The one-bit doubling described above remains the default subsequent
> allocation size where eligibility is based on acceptable utilization alone.
>
>
>
>     Where an account holder explicitly requests nibble-boundary alignment
> for a subsequent allocation larger than the default doubling, it must
> provide a long-term IPv6 address plan as part of the documentation
> justifying its new requirements.
>
>
>
>     After APNIC validates the larger requirement:
>
>
>
>     1. Where possible, the subsequent allocation will result in the
> expansion of the existing allocation by one or more nibble boundaries, as
> justified by the validated requirement.
>
>
>
>     2. If the existing allocation cannot be expanded, or cannot be
> expanded adequately to meet the validated requirement, APNIC may make a
> separate new allocation using a nibble-boundary aligned block sufficient to
> satisfy the validated additional requirement.
>
>
>
>     If nibble-boundary alignment is not requested, the subsequent
> allocation will continue to be processed under the existing one-bit
> doubling and needs-based sizing rules in this section.
>
>
>
> This amendment preserves one-bit doubling as the default subsequent
> allocation mechanism.
>
>
>
> An account holder cannot obtain a substantially larger allocation solely
> because it prefers nibble-boundary alignment. A request larger than the
> default doubling must first be supported and validated under the existing
> needs-based criteria.
>
>
>
> The wording follows the operational structure used in ARIN policy: expand
> the existing allocation where possible and, where sufficient expansion is
> not possible, make a separate allocation of the size justified.
>
>
>
>
>
> 4.4 Sections and mechanisms not amended
>
>
>
> This proposal makes no text change to:
>
>
>
>     - Section 8.2.1, Account holders with existing IPv4 space;
>
>     - Section 8.2.2, Account holders without existing IPv4 space;
>
>     - Section 8.3.1, Existing IPv6 address resource holders;
>
>     - Section 8.3.2, Applied HD-Ratio;
>
>     - Section 8.3.3, Alternative allocation criteria; or
>
>     - Section 9, IPv6 assignments.
>
>
>
> The following existing mechanisms also remain unchanged:
>
>
>
>     - the /32 minimum IPv6 allocation;
>
>     - the HD-Ratio value and utilization thresholds;
>
>     - one-bit doubling as the default subsequent allocation size;
>
>     - APNIC's Sparse Allocation Framework; and
>
>     - the exception for multiple discrete networks.
>
>
>
>
>
> 5. Advantages / Disadvantages
>
> -----------------------------
>
>
>
> Advantages
>
>
>
>     - Establishes a clear Section 8 allocation mechanism
>
>
>
>       The proposal gives APNIC, NIRs, LIRs, and request evaluators a clear
> policy basis for considering nibble-boundary alignment instead of treating
> it only as an informal operational preference.
>
>
>
>     - Improves operational clarity
>
>
>
>       Nibble-boundary aligned blocks are easier to read, document, verify,
> subdivide, and process in IP address management, automation, logging,
> routing policy, security segmentation, reverse DNS, and audit systems.
>
>
>
>     - Supports hierarchical planning and aggregation
>
>
>
>       Nibble-boundary alignment provides a clearer basis for dividing
> address space by geography, network layer, service, security domain, site,
> or customer group while preserving cleaner aggregates for routing and
> long-term internal planning. The proposal does not regulate BGP
> announcements, but it improves the address-planning conditions that support
> aggregation.
>
>
>
>     - Reduces repeated incremental expansion
>
>
>
>       Where a larger requirement has been validated, expansion of the
> existing allocation by one or more nibble boundaries, as justified, may
> reduce repeated small subsequent requests, administrative overhead, future
> fragmentation, and the risk of renumbering.
>
>
>
>     - Preserves needs-based safeguards
>
>
>
>       The proposal does not allow nibble-boundary alignment to substitute
> for eligibility, utilization, HD-Ratio, or documentation requirements. The
> underlying requirement must be validated before alignment is applied.
>
>
>
>     - Preserves existing policy scope
>
>
>
>       The proposal does not amend Section 9 assignments, reduce the /32
> minimum allocation size, or alter the default one-bit doubling mechanism.
>
>
>
>
>
> Disadvantages
>
>
>
>     - Larger address blocks in some cases
>
>
>
>       Nibble-boundary alignment may result in the delegation of more
> address space than the exact non-aligned calculated requirement. For
> example, where a calculated requirement is larger than /32 but can be
> satisfied by /30, the smallest nibble-boundary aligned block that can
> satisfy that requirement is /28.
>
>
>
>       The additional address space results from alignment to the
> applicable nibble boundary. It is not an independent justification for a
> larger underlying requirement.
>
>
>
>     - Resource-management and system impact
>
>
>
>       APNIC and NIRs may need to update request-evaluation procedures,
> registration systems, internal tools, and operational guidance to support
> nibble-boundary alignment consistently.
>
>
>
>       Existing sparse allocation spacing may not always provide sufficient
> adjacent address space for the requested expansion. In those cases, a
> separate allocation may be required.
>
>
>
>     - Possible fee impact
>
>
>
>       Where membership tiers or fees are affected by the total IPv6
> address space delegated to an account holder, nibble-boundary alignment may
> result in a higher fee category.
>
>
>
>       APNIC and the relevant NIR should assess this impact and inform an
> applicant of any material fee consequence before the applicant accepts a
> nibble-boundary aligned allocation.
>
>
>
>     - Implementation discretion
>
>
>
>       The terms "will normally", "the smallest nibble-boundary aligned
> block", "one or more nibble boundaries, as justified", and "where
> operationally practicable" require implementation judgment.
>
>
>
>       APNIC may need to publish implementation guidance to promote
> consistent evaluation across APNIC and NIR workflows.
>
>
>
>
>
> 6. Impact on APNIC
>
> ------------------
>
>
>
> Existing resource holders will not be required to renumber, return, or
> resize IPv6 allocations delegated before implementation of this proposal.
>
>
>
> For initial allocations, the existing eligibility and needs-based
> assessment remain unchanged. Where a larger initial allocation has been
> validated and the applicant explicitly requests nibble-boundary alignment,
> APNIC will normally delegate the smallest nibble-boundary aligned block
> that can satisfy the calculated address requirement.
>
>
>
> For subsequent allocations, one-bit doubling remains the default where
> eligibility is based on acceptable utilization alone. A request for a
> larger nibble-boundary aligned allocation must satisfy the existing
> documentation and needs-assessment requirements.
>
>
>
> After the larger requirement has been validated, where possible, the
> subsequent allocation will result in the expansion of the existing
> allocation by one or more nibble boundaries, as justified by the validated
> requirement. If the existing allocation cannot be expanded, or cannot be
> expanded adequately, APNIC may make a separate allocation of the size
> justified, on a nibble boundary where operationally practicable.
>
>
>
> IPv6 assignments under Section 9 remain outside the scope of this proposal.
>
>
>
> Where an allocation request is processed through an NIR, the NIR will
> implement this mechanism through its local operational workflow, subject to
> the same policy safeguards and applicable APNIC-NIR operational procedures.
>
>
>
> APNIC and NIRs may need to update request-evaluation procedures,
> registration systems, internal tools, and operational guidance to support
> nibble-boundary alignment consistently. APNIC and the relevant NIR should
> also assess whether nibble-boundary alignment has any material fee
> consequence for an applicant before the applicant accepts the allocation.
>
>
>
>
>
> References
>
> ----------
>
>
>
> APNIC Internet Number Resource Policies, Sections 3.1.7, 5.1.2, 8.0, 8.1,
> 8.2.1, 8.2.2, 8.3.1-8.3.4, and 9:
>
> https://www.apnic.net/community/policy/resources/
>
>
>
> APNIC Guidelines for IPv6 Allocation and Assignment Requests:
>
>
> https://www.apnic.net/about-apnic/corporate-documents/documents/resource-guidelines/ipv6-guidelines/
>
>
>
> ARIN Number Resource Policy Manual, Sections 6.5.1, 6.5.2.1, 6.5.3, and
> 6.5.8.3:
>
> https://www.arin.net/participate/policy/nrpm/
>
>
>
> RIPE-738, IPv6 Address Allocation and Assignment Policy:
>
> https://www.ripe.net/publications/docs/ripe-738/
>
>
>
> RIPE Policy Proposal 2024-02, IPv6 Initial Allocations /28 and Extension
> to /28, withdrawn 26 February 2026:
>
> https://www.ripe.net/community/policies/proposals/2024-02/
>
>
>
> RIPE Policy Proposal 2024-01, Revised IPv6 PI Assignment Policy:
>
> https://www.ripe.net/community/policies/proposals/2024-01/
>
>
>
> APNIC prop-164, Allocations of IPv6 Resources Longer Than a /32 with
> Nibble-Boundary Alignment:
>
> https://www.apnic.net/community/policy/proposals/prop-164/
>
>
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-- 
--
Satoru Tsurumaki
BBIX, Inc
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