[ARIN-consult] Consultation on ARIN Fees

John Curran jcurran at arin.net
Thu Apr 15 12:09:30 EDT 2021 

Glen -

Great feedback - thanks for taking the time to write this up!

/John

John Curran
President and CEO
American Registry for Internet Numbers


On 15 Apr 2021, at 9:40 AM, Glen A. Pearce <arin-consult at ve4.ca<mailto:arin-consult at ve4.ca>> wrote:

I'm a 3x-Small organization (literally "the smallest end users" to
borrow Owen DeLong's terminology) chiming in.

After a few years of reading NANOG I came to the conclusion that the
IPv4 to IPv6 transition was going to be long, slow and potentially
ugly.  So this is why I chose to get my own resources directly from
ARIN to cover both bases.

-My own IPv4 space so I can go to any ISP that can provision
 connectivity to my location whether they have IP space of their
 own available or not.  If one or both of the big guys in my
 market ends up doing carrier grade NAT badly (especially by
 surprise) or just starts price gouging for IP addresses the
 independents will probably have a hard time getting enough
 IPv4 space to take the exodus of customers at that point.
 (It's even possible the transfer market could at some point
 lock up with no blocks offered for stretches of time.)  A guy
 that's bringing his own space and just needs bandwidth will
 be a lot easier to take on.

-Getting IPv6 before my local cable company gets around to
 implementing it.  Much easier to get dual stacked and slowly
 transitioning stuff on my network and have time to get used
 to everything than having to scramble to do it all at once
 when/if things finally tip from glacial movement to rapid change.

On Fri, Apr 9, 2021 at 3:38 PM ARIN <info at arin.net<http://arin.net>> wrote:

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

Largely I'm OK with this as I recently converted to a registration
services plan myself as I was wanting to get IPv6 space as well so
it made more sense to have both and full voting membership under a
single $250 fee.  (I just submitted a ticket asking about getting
a /40 yesterday morning,)

As one of "the smallest end users" I don't need more than a /24 of IPv4
space and a /40 of IPv6 space.  If the nature of what I do changed
enough that I needed more space than that I would probably by that
point be a big enough organization that I could handle the higher
fees for the larger chunks of IP space under the Registration
services plan.

Really this will only raise costs for end user organizations with
very large singular chunks of space.  Generally an organization big
enough to actually need even a /22 is big enough it can afford to
pay the Registration Services Plan fees for it.

It won't impact us "smallest end users" with the possible exception
of holders of a single IP block.  This could maybe be addressed by
making the "ASN-only" category in the proposed new fee structure a
"single resource only" category which would apply whether that single
resource was an AS, a /24 of IPv4 or a /40 or smaller of IPv6.

The IPv4 only holders will eventually realize one day that they
need IPv6 as well to be visible to the whole internet and they
will upgrade then at their own pace.  I'm pretty sure that anyone
that at this point has their own IPv6 space and no IPv4 space is
either running a hobby/experimental network or is thinking very
very long term about larger plans and is thinking it's easier to
get their resources now than down the road, either way they
probably aren't generating revenue with that IPv6 block right
now so for them every penny counts.

Finally having everyone under the registration services plan will
be simpler for new sign ups than having 2 different fee schedules.

    * 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)

As long as the fee cap on LRSA holders remains (which I agree it
should for all of them and not just the early signers) that would
override the difference between the 2 current fee schedules anyways
which makes this change immaterial to them.

Legacy holders (including those that never signed an LRSA) will all
at some point need IPv6, so either they'll have to get it through
their ISPs or they'll have to pay RIR fees on those when the point
comes that they decide they need it.

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

Generally I think this is a gimmick, it expires at the end of 2026.
Really if I needed more than a /40 of IPv6 space between now and
the end of 2026 I'd probably also need more IPv4 space and have
to move up size categories anyways.  It almost looks like a trap
as anyone who takes the bigger space now but doesn't really need
it is baking in a doubling of fees when they renew in 2027 but if
their organization is still a very small one that doubling of fees
could be a strain on them.  I myself did hold out for the 2020-3
to be implemented before requesting IPv6 space as $250/year I can
handle but $500 per year would be a strain.

    * Implementing a $100 fee for OrgCreate and OrgRecovery
      transactions

Although I see this maybe being a thing for OrgRecovery as I imagine
most of these are for Orgs with legacy resources where there is a
strong incentive for someone to try hijacking the Org so an extra
level of scrutiny is probably needed....

However I'm thinking for OrgCreate for an entirely new Org if it's
taking $100 of labor to do this something is wrong with the process
and it needs to be streamlined somehow.

I mean for my .ca names I have to be Canadian to hold them but if
people had to start paying CIRA $100 to verify their Canadianness
before they could get a .ca name that wouldn't go over well. ^_-

So I would tend to oppose this fee at least fora  brand new OrgCeate.

    * Increasing the transfer processing fee to $500

This seems reasonable.

--
Glen A. Pearce
gap at ve4.ca<mailto:gap at ve4.ca>
Network Manager, Webmaster, Bookkeeper, Fashion Model and Shipping Clerk.
Very Eager 4 Tees
http://www.ve4.ca<http://www.ve4.ca/>
ARIN Handle VET-17

--
Glen A. Pearce
gap at ve4.ca<mailto:gap at ve4.ca>
Network Manager, Webmaster, Bookkeeper, Fashion Model and Shipping Clerk.
Very Eager 4 Tees
http://www.ve4.ca<http://www.ve4.ca/>
ARIN Handle VET-17

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