[arin-announce] Consultation on ARIN Fees

[Owen DeLong]

> On Apr 9, 2021, at 1:10 PM, ARIN <info at arin.net> wrote:
> 
> ARIN’s Fee Schedule has always been based on the principle of equitable cost recovery across our community through a stable and consistent fee schedule. In general, this means that ARIN has avoided making routine changes to the Fee Schedule (for example, making annual readjustments for changing costs) and instead has only made changes when deemed necessary.
> 
> We are consulting with the community regarding changes to the ARIN Fee Schedule that are intended for implementation in January of 2022. These changes are:
> 
>    * Transitioning End Users from annual per-resource maintenance fees to the RSP (Registration Services Plan) Fee Schedule

Opposed unless the RSP fees for ≤/22 (v4) and/or ≤/36 (v6) are reduced to ≤$250 … This subsidizes ISPs on the backs of end users by making the minimum charge for an end-user much higher.

For example, an end-user who currently has a /22 and a /48 would be charged $300 under the current structure and $500 under the RSP.

While it does come with the advantage of ARIN membership, the reality is that if End Users felt that was worth $500 per year, we would already have many more end users opting into the RSP. Many end user organizations who have smaller blocks (e.g. ≤/22 of IPv4 space) would, therefore, be facing a significant annual increase in costs.

What percentage of end users have opted into this program voluntarily? Especially considering how ARIN has essentially buried information about this option for end users looking for it on the fee structure page, if it’s not extremely high, I would say that’s a pretty clear case for not inflicting it upon them unless there is some reduction in the current RSP pricing at the lower tiers to compensate for this.

>    * Transitioning Legacy resource holders from annual per-resource maintenance fees to the RSP Fee Schedule while maintaining the annual cap of total maintenance fees (which will increase $25 per year)

LRSA signatories should not be treated differently from RSA holders other than living up to the agreed upon $25/year cap on fee increases. 

>    * Providing a temporary IPv6 fee waiver for organizations in the 3X-Small category that desire a larger address block

I would rather see the 3X-small category permanently increased to encompass /36. I would be willing to accept a structure where ARIN caps the 3X-small category based on the NRPM defined PAU and limits the category to 4096 PAUs rather than a straight /36. This would remove financial incentives for providers to short-change their end-users and remove current financial disincentives for smaller providers to implement IPv6, while preventing the perverse financial incentive for larger providers to try and squeeze more than 4095 customers into a /36.

>    * Implementing a $100 fee for OrgCreate and OrgRecovery transactions

I have no problem with this idea.

>    * Increasing the transfer processing fee to $500

I support this idea.

> As the use of the ARIN registry continues to grow, we continue to invest in our services in order to meet the changing needs. One significant change we have seen with the runout of IPv4 is the maturity of the transfer market, a development which has enabled better overall utilization of the fixed IPv4 address space and led to reutilization of IPv4 resource assignments to meet the growing needs of organizations of all types. ARIN provides equivalent services to end users and ISP customers, but it has had two very distinct fee schedules due to historical difference in use. For example, our investment in the ARIN Internet Routing Registry (IRR), Resource Public Key Infrastructure (RPKI) and DNSSEC services improve network security across the Internet and are being used by all types of ARIN customers. However, in many cases, organizations receiving similar services from ARIN are paying significantly different fees today – for example, two hosting companies each with the same 65,000 IPv4 addresses (/16) may find that one is paying more than 25 times as much as the other despite receiving the same services from ARIN.

In general, end users are not expected to be submitting reassignments and cannot reallocate space. As such, their use of services like RPKI and DNSSEC should be much much simpler than the use of a dynamic ISP with high rates of customer churn, active SWIPS, multiple updates to ROAs, etc.

I would expect that the majority of end-users would require relatively few database updates, often going multiple years between significant changes whereas an ISP that goes more than a month or two without any required updates would be quite a surprise.

> In 2022, ARIN will transition all customers to the RSP fee schedule based on total IPv4 and IPv6 resources held. This change will ensure costs are distributed in an equitable manner by eliminating the current fee differentiation between ISP and end user organizations.

Given the fact that there still remains a significant difference in the profile of ARIN service utilization between ISPs and those who should qualify as end users under policy, I think this is a very misguided use of the term “equitable”.

Equal isn’t always equitable. Asking a small entity running a SMB that requires an internet presence, but is not in the business of providing internet services and is not actively interacting with ARIN databases on a frequent basis to pay the same amount as an ISP who is handling tens of transactions in the ARIN databases per month may be equal, but is not, IMHO, equitable.

> The proposed fee change also brings those with resources issued before the formation of ARIN (legacy resource holders) into the new Fee Schedule, thus providing for uniform treatment of all ARIN customers. Legacy resource holders have enjoyed a cap on total registry maintenance fees, and this continues to be applied under the new Fee Schedule, although it is also made clear that the total cap will increase $25 per year, thus recognizing the contribution of the earliest Internet pioneers while enabling a long-term transition to equitable fees for all.

There are two classes of legacy resource holder today. There used to be 3.

There are the ones who were smart enough to see the traps inherent in the LRSA and refused to sign and therefore still pay no fees and there are the ones like me who made the mistake of signing it. The third category used to be those who signed a later version of the LRSA without the fee cap in the language and really got shafted for a few years before the cap was reset.

LRSA signatories (which are the only legacy resources the above statement is applied to) signed an agreement with the understanding that end users paid a single annual maintenance fee of $100 with the expectation that that fee could only go up by $25/year. Further, if they had non-legacy end-user resources, they were convinced that said fee was one and the same with the fee they would have to pay for their non-legacy resources. (ARIN staff spent a great deal of time explaining it to the community in these terms). Why not bring your legacy resources under LRSA… It won’t cost you any more than you’re paying for your non-legacy resources anyway.

A few years later, ARIN shifted end users from a single fee per account to separate fees for each resource. At that time, they forced LRSA signatories that had RSA resources as well into becoming two organizations (e.g. EXAMPLE and EXAMPLE-Z) which were billed separately. The EXAMPLE org fees only went up $25/year, but EXAMPLE-Z was suddenly charged separately at the full $150 rate, so and org with 3 resources (2 LRSA and 1 RSA) that was paying $100/year was suddenly on the hook not for $125/year, but $275/year — $125 for the LRSA and $150 for the RSA.

> In addition, it has been recognized that the increased numbers of transfers and related organizational record changes take significant ARIN resources, and could result in extended processing times without appropriate resources. This is addressed with fee changes in those specific transaction types to allow ARIN to continue to continue to provide timely services with equitable cost recovery.

I support increasing transfer fees and ORG creation/recovery fees to truly recover the costs of all transactions related to transfers. I would, however, advocate for a fee credit for ORG creation fees where there is an IPv6 initial allocation within 3 months of ORG creation and said ORG does not engage in transfers during their first year. A truly new organization should not be required to subsidize the transfer market.

> Finally, in response to a suggestion from the community, the ARIN Board of Trustees proposes a temporary waiver with regard to fees applicable to those requesting very small IPv6 blocks in order to avoid a fee category change, and the new Fee Schedule includes a specific waiver to address this situation.

The community has asked you to solve the fee step-up problem that blocks providers from adopting IPv6 because a provider that is doing just fine on a /24 of IPv4 can’t get less than a /36 and doing so would double their ARIN annual fees.

A temporary fee waiver is a pretty poor response IMHO. It will be easily seen through as a band-aid that provides no real relief. Instead, it hopes to paper over the fee step-up and then once these providers have deployed IPv6 and have no way back, at the whim of the ARIN board, their fees still end up doubling. What is needed is a permanent solution to a disparity in fees for very very small ISPs.

> These changes have the added benefit of allowing ARIN to maintain robust and redundant operational infrastructures, so that we can guarantee our services are online and accessible at all times. It will also allow ARIN to continue to develop and provide the high-quality services demanded by our customers and the Internet community, including our routing security services which are increasingly crucial to all of our customers.

Can the board let the community know how much revenue increase is expected from each of these proposals? Can the board also compare and/or contrast that to the following alternatives:

1.	Reduce the 2X category to $250/year and eliminate the 3X category.
	Increase fees for Large and above by 1%.

	Advantages: Instead of subsidizing larger organizations that have exponentially more use of ARIN services
	and a great deal of transaction activity in ARIN databases at the expense of very small organizations, a
	relatively modest increase ($2,560 for an organization holding a /6 or ore and $800 for an organization holding
	more than a /16 but ≤/14) might provide a more equitable (though admittedly less equal) cost burden.

2.	Instead of forcing end-users into an RSP, return to per-org pricing, but at $300/year per org with ARIN
	membership as a benefit. ORGs which have both RSA and LRSA resources would have the option
	of consolidating into a single ORG and paying $300/year or maintaining the current split system and
	paying $300/year for their RSA org and paying $25/year more each year for their LRSA ORG until
	reaching parity with the RSA fees.

	Such option to be reversible any time the fee structure is changed in the future.

	Raise the transfer fee to $750 and increase the new-org fee to $250. For a new org which receives
	an IPv6 initial allocation within 3 months and does not engage in transfers during their first year,
	apply the $250 to their renewal fees for the second year.


Owen