[ARIN-consult] Consultation on ARIN Fees

John Curran jcurran at arin.net
Mon Apr 12 17:45:02 EDT 2021

On 12 Apr 2021, at 4:35 PM, Richard Laager <rlaager at wiktel.com<mailto:rlaager at wiktel.com>> wrote:

I think we're on the same page that there are four categories relevant here:

1: Legacy holders with no agreement: $0

2: Legacy holders with older LRSA: $125 + $25/year until regular fee; takes e.g. 300 years.

3: Legacy holders with newer (L)RSA: ARIN proposed $125 + $25/year until regular fee; takes e.g. 300 years. I proposed: $125 + something/year until regular fee; takes e.g. 10 years.

4: Non-legacy holders with RSA: regular fee

Richard -

Thanks for taking the time to write this - I believe your categorization is quite helpful.

You have noted that category 1 is significant. But if ARIN is not able or willing to compel them to pay fees, that's mostly irrelevant for this discussion. I realize that raising fees on category 3 disincentives organizations in category 1 from signing, but if they haven't by now, I'm not sure what else can be done to make them (and this isn't that discussion anyway). If fees are the reason, you can't unring that bell; they presumably understand the stated intention to harmonize fees whether you actually make this move now or not, and on what schedule.

The 732 customers who have over the past decade have entered into an LRSA with ARIN have done so for a variety of reasons:

- They’d like to have some clear legal documentation of their rights to the asserted entries in the ARIN registry
- They desire some newer services that ARIN does not provide except under RSA (e.g. RPKI)
- They wish to support ARIN as an organization and feel paying ’their share’ is reasonable and customary

Recognize that these legacy resource holders entered into agreements with ARIN in good faith, particularly considering that ARIN was at the time providing the vast majority of services to them (ARIN Online, updates, Whois publication, reverse DNS) to them at no charge, and all of them have terms to the effect that their fees "will not exceed the fees charged to comparable non-legacy holders for registration services as set forth in ARIN’s Fee Schedule for comparable number resources.”  Note also that more than 400 of them are very early LRSA signatories and thus their agreements provide that total fees cannot increase more than $25/year.

I didn't see any answer to my question about whether categories 2 + 3 are material on fees. I want to be pragmatic here; if this is costing category 4 organizations $10/year more, it's probably not worth arguing about. But absent an answer, I guess I'll assume it is material?

Legacy holders who moved from category 1 to 2 or 3 by signing an LRSA might consider that to have been a bad idea and that the results are unfair relative to their original state 1, now that they're being asked to pay more. While I understand their position, I have little sympathy for it, given that they are asking others to subsidize them indefinitely.

I do have sympathy for them regarding a sudden large increase. A one year jump seems unreasonable. That's why I proposed a longer, but still reasonable timeframe of e.g. 10 years. Whatever happens, I also encourage ARIN to work with any that wish to voluntarily accelerate the transition, as David Farmer brought up.

I, as someone who works at a company in category 4, consider the continued existence of the other categories inequitable. Legacy holders, in many cases, received large allocations (which, if not fully utilized, now have significant resale value). We can't change that, any more than the fact that some organizations previously received allocations from ARIN for free and now we have to pay on the transfer market. (My employer has both.) But that's different from an ongoing inequitable annual cost recovery, which can be addressed.

These legacy customers currently pay $109,800 per year in total, and this goes up by $18,300 each year the Board raises the total fee cap by $25 (which it has done twice so far.)    As a result of the fee consultation, this cap will increase every year on a consistent basis by $25, and over (a very long) time will result in similar fees to all other customers.  Because of the relatively high number of LRSA customers with the $25 annual increase cap, it is unclear if there is a viable strategy for changing these fees any faster (and as you note, it will discourage other legacy resource holders from considering entering into the LRSA agreement with ARIN.)  It’s worth noting that there are an increasing number of legacy resource holders now entering into an LRSA with ARIN  – this could out of the desire to transfer some of their resources, use some of our more advanced registry services, or both.

You have been "handling it as if [the $25/year cap was] present for all LRSA agreements to maintain equitable fees for similar customers in comparable situations". I understand that you consider "legacy resource holder" to be "similar customer" here. From my perspective, we are all similar customers. (I realize that category 1 is a bit different, as they may not get full ARIN services.)

Removing the $25/year cap from the agreements was not an accident. ARIN did this for a reason, AFAIK specifically to allow eventually harmonizing the fees. Now you are there, but you are proposing to not do so even in cases (category 3) where you could.

I maintain my position that you should harmonize the fees faster, where contractually permitted.

I appreciate (and share) the desire to harmonize fees across ARIN, and the proposed fee change is a step in that direction.  While not part of this consultation, ARIN will shortly be reviewing the uncontracted services provided to legacy resource holders and considering questions such as whether if it is responsible for ARIN to continue to provide these services indefinitely without fee or contract.  I would ask that we defer our discussion of cost recovery for legacy resource holders to that time, and note that the current proposed fee change is a step in the right direction by at least getting ARIN to a single fee schedule.


John Curran
President and CEO
American Registry for Internet Numbers

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