[ARIN-consult] Fee Schedule Change Consultation

[John Curran]

On Oct 30, 2012, at 9:24 AM, Owen DeLong <owen at delong.com> wrote:

> Under the proposed fee structure, this would go from <$1.4M to nearly $4M, mainly due to the increase as a result of charging per ASN ($1M vs. what is likely now $0). Given the number of ASNs listed, however, I suspect that this charge is distributed among both End-Users and ISPs and that ISPs pay for each ASN in addition to their IP Address subscriptions. (10,416 ASNs vs. 3,500 End-user ORGs). (Page 14 of the same document).

Owen - ISP registration service subscription plans include maintenance for 
all number resources including ASNs, i.e. the 10,416 ASN maintenance fees 
are simply for end-user held ASNs. 

> In other words, the entire structure is a proposal to provide relatively small discounts to most ISPs at the cost of putting a huge additional burden on end-users and ISPs that happen to fall into the wrong side of fee-bucket-realignment.

What you characterize as a "huge additional burden" is the establishment
of a maintenance fee for each resource held, as opposed to a single $100 
maintenance fee for unlimited number of resources.  

Any change to the fee schedule which establishes fees which increases with
resources held will have this type of impact, but the alternative is a fee
schedule which does not fairly recover costs in proportion to resources held. 
As the vast majority of end-user organizations have a small total number of
resources held, this is almost always a modest increase of several hundred 
dollars per year.  If indeed we include one of each IPv4/IPv6/ASN in the 
initial $100 maintenance fee, then even fewer organizations will see such 
an increase under the proposed revision to the fee schedule.

As discussed, here is the distribution of total number of IPv4+IPv6+ASN 
resources held by end-users under an RSA agreement (excludes LRSA held
resources as their total fees paid will change over multiple years) -

# - Count of End-User Organizations with that total number of resources.

1 - 11658
2 - 423
3 - 669
4 - 135
5 - 97
6 - 40
7 - 26
8 - 15
9 - 8
10 - 11
11 - 11
12 - 6
13 - 4
14 - 1
15 - 5
16 - 1
17 - 1
18 - 2
20 - 2
21 - 1
23 - 1
28 - 2
31 - 1
32 - 2
35 - 1
38 - 1
45 - 1
54 - 1
55 - 1
59 - 1
75 - 1

The large number of organizations with just 1 resource are due to the number 
of organizations which simply have a single AS# (and likely are either legacy
resource holders or using provider-assigned address space for connectivity)

> I will point out that for the most part, only 56 very large ISPs are in this category and their fees double from $16,000/year to $32,000/year (with the possible additional cost of $100/asn on top of that).

Incorrect - more than 500 ISPs (out of a total of about four thousand ISPs) see 
an increase under the proposed revision to the fee schedule, and this enables 
the reduction in the fees seen by the fifteen hundred xx-small and x-small ISPs 
(to $500 per year and $1000 per year respectively); this is one of the explicit 
goals of the proposed revision to the fee schedule.

FYI,
/John

John Curran
President and CEO
ARIN