[ARIN-consult] Consultation on ASN Fee Harmonization

[Ross Tajvar]

Hi all,

While I do think there's merit to Steve's point that ASN-only customers
have chosen not to become members, I have to say, I would care about this a
lot more (at all, really) if the fees were higher. For a business doing
anything real, $250/yr is negligible. Even $500 or $1000 is not a big
deal...keeping an LLC open costs a few hundred dollars a year. Buying
transit (in order to use the ASN) costs a couple hundred dollars a MONTH.

I understand that there is administrative overhead associated with
maintaining a registry of internet numbers, keeping whois services highly
available, handling support requests, etc. ARIN must recover these costs by
charging fees to its customers. I couldn't say what the average cost per
ASN is (maybe John has some estimate there?), but $250/yr for up to 3 ASNs
does not seem wildly unreasonable to me.

I also think there is value in the added simplicity achieved by adopting a
unified fee structure.

For these reasons, I take no issue with this proposed change.

Best regards,
Ross

On Mon, Jul 10, 2023, 11:48 PM Steve Noble <snoble at sonn.com> wrote:

>
>
> On Jul 10, 2023, at 3:02 PM, John Curran <jcurran at arin.net> wrote:
>
> On Jul 10, 2023, at 2:28 PM, Steve Noble <snoble at sonn.com> wrote:
> ...
> I have a lot of questions:
>
> 1. The above paragraph states that there are approximately 6800
> organizations holding a single ASN and more specifically 313 with multiple
> ASNs, what is the actual number of organizations with a single ASN and no
> other resources?
>
>
> Steve –
>
> The ~6800 are ASN-Only holders (no IPv4 or IPv6 resources) with a single
> ASN.    The 313 are ASN-Only holders (no IPv4 or IPv6 resources) who have
> multiple ASNs.
>
>
> John -
> You did not answer the question, the 6800 is approximate, ARIN must know
> the actual number.
>
> 2. How many single ASN holding organizations are members of this mailing
> list?
>
>
> Unknown.  The arin-consult mailing list is open to all interested parties
> who comply the Mailing List AUP and ARIN Participants Expected Standards of
> Behavior – these are not correlated to ASN holders.
>
>
> This is concerning since 6800+ organizations would be affected and may not
> know so since they have not been members and would not be part of the
> members mailing list, etc.
>
>
> 4. The customer impact is significantly unbalanced where over 95% of the
> organizations fees increase vs the 2021 changes (
> https://www.arin.net/participate/meetings/ARIN49/materials/426_feemembership.pdf slide
> 7) where ~50% stayed the same. Why is this not clearly stated in the
> document?
>
>
> That’s not quite correct - ASN Only Holders represent 30% of total
> customers [where total customers are Service + General + ASN Only.]
>
> (If one adds uncontracted legacy customers to that total, ASN-Only holders
> represent only ~18% of total customers.)
>
>
> John, I am talking about the affected parties, the ~7113 ASN-Only holders,
> 95% of them will be affected negatively.  What percentage they are of the
> total number of customers is moot as the document I point to clearly states
> :
>
> "● Transitioned all customers with IPv4 or IPv6 number resources to the
> same RSP (Registration Services Plan) Fee Schedule:”
>
> This does not cover ASN only holders.  If ASN only holders were included
> in the not affected list and chart that would be incorrect as they were not
> included in the list of customers this was positioned as being.
>
>
> 5. Of the impacted organizations, how many pay for membership separately?
>
>
> None, as paid membership was removed as part of the 2022 fee schedule
> change. This change (ASN Fee Harmonization proposal) in fact provides
> Service Member status to all ASN holders.
>
>
> So accordingly, zero ASN only organizations applied to be members, I don’t
> see how forcing them to pay more for something that they never applied for
> is a valid benefit.
>
>
> 6. Of the impacted organizations, how many have requested IPv4 resources?
>
>
> Indeterminate, as it is often possible to request resources without
> supplying ASN holding information and thus correlated.
>
>
> ARIN should know how many ASN only members requested IP addresses at least
> on an org level.  If the ASN belongs to a different organization, that
> would not apply here as we are talking about organizations that only hold
> ASNs.
>
>
> 7. What is the overlap of single ASN holding organizations paying for
> membership and requesting IP space (two items claimed in the benefit
> section).
>
>
> No one is paying for ARIN Membership since the 2022 fee schedule change
>
> (All organizations holding IP number resources under agreement have had
> service member status since Jan 2022, and can request General Member status
> if they wish to participate in voting & ARIN governance discussions).
>
> ASN-Only holders will now have Service Member status as part of the ASN
> Fee Harmonization proposal AND will be able to request corresponding IPv4
> and IPv6 space if they choose with no change in fee category.
>
>
> But according to above you have provided information that zero ASN only
> organizations that have done this so far, so ARIN is forcing ~6800
> organizations to pay more for a benefit that they have not requested.
>
>
> 8. For due diligence, based on the data ARIN has compiled, how many of
> those single ASN organizations would qualify for IPv4 resources and be
> approved and have them allocated within the billing period that this change
> would happen? Does ARIN have 6800 /24 IPv4 blocks available to allocate to
> the affected parties?
>
>
> They would all qualify for IPv4 or IPv6 if they are running a network and
> using their ASN to run BGP.   It probably goes without saying that there is
> more than enough IPv6 resources for all ASN-only customers...
>
> For IPv4 resources, many would end up on the IPv4 waiting list today, but
> note that for those who wish to run IPv6, there is enough 4.10 transition
> IPv4 space (~14.5k /24s are available under 4.10 as of June 2023) to
> theoretically issue 4.10 IPv4 transition blocks to all of the ASN-Only
> holders.
>
>
> I think that is a false equivalence comparing transition space to
> available space. For example I applied for my ASN 23 years ago, IPv4 space
> was much easier to get.  Had you charged the same fee whether I had space
> or not, I would have applied for space.
>
>
> In summary, based on the information provided so far, I believe that
> raising prices for 6800+ organizations to slightly lower the cost burden of
> 313 is unfair and unreasonable. There has been no data provided to show
> what the cost of serving a single ASN organization is other than your
> aggregate groups showing that it is <=$15.
>
>
> This change provides for recovering costs more equitably for services to
> across the ARIN customer base, with the added benefit of making ASN-only
> customers ARIN Service Members, thus providing them with the opportunity to
> become General Members and participate in ARIN governance if they so choose.
>
>
> John - How much does it cost to provide service to an ASN only holder?
> What actual, tangible benefit do they get with this change?  The affected
> organizations could have asked to be members or for IP space the entire
> time.  There is no upside to this that has been documented and it’s
> certainly all negative from my position.
>
>
> In addition to bringing all ARIN customers into a unified, equitable fee
> schedule, the ASN Fee harmonization will facilitate ASN-only resource
> holders obtaining IPv4 and/or IPv6 resources if they choose to do so.
>
>
> And to this point they should be able to choose, If an ASN only
> organizations wants resources or to be a member, they can pay more.  If
> they want to stay how they are they can stay how they are.  Forcing ASN
> only organizations to foot the bill for those who have or want more is not
> equitable.
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