David,
I have in principal support for this proposal, I think it is a good policy for all the points you outline. However I would like some clarification on the two points below.
4 D. The minimum IPv6 portable assignment to any organization is to be
an address block of /48. A portable assignment of a block larger
than a /48 can be made if it can be demonstrated that more than
32,768 /64 subnets (or equivalent) are required within its network
or if numbering is required for 2 or more of the organization's
sites operating distinct and unconnected networks.
Can you explain the logic/choice behind the choice of 50% allocation rate (32768 / 65536) for a /48?
Also does this not go against the underlying HD ratio for an IPv6 allocation of this size ? By my (possibly bad) math should this not be 33689 /64s ? or align to the the equivalent of 184 /56s as per the current IPv6 address policy ?
4 F. An organization must only use portable assignments made under
this policy to address its own networks. An organization must
not use portable assignments to address the networks or sites of
other organizations.
Whilst I agree with the intent that the recipient of the PA address space should not act as an LIR/ISP I don't see that the wording of this specific point is commercially viable in that context. What about in the case of Joint Ventures, or foreign owned entities ? Where there is likely to be a commercial relationship between two organisations, however possibly no direct parent-child hierarchy ? The reality is that if the 'other organisation' gets a /48 form the owner of the PA, or receives a unique allocation from APNIC or another RIR the effect on the routing table will remain the same.
Cheers