[ARIN-consult] Consultation on ARIN Fees

[Owen DeLong]

>> 
>> 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. 

Yes, but the reality is that as soon as you have a /23 + 1 address
(e.g. a /23 + a /24), you get jacked.

To make matters worse, if you have LRSA and RSA resources, you
get double-jacked because ARIN can’t figure out how to bill you for
the MAX you owe under either of the two contracts, so they bill you
for both. You can consolidate under an RSA, but then your LRSA
resources no longer have the protection of the $25/year cap on
increases.

As a result, you get converted not to a single RSP, but to two RSPs.

>> 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. 

In reality (and this might be worth considering), the current fee structure
plan creates an economic incentive for LRSA holders to abandon any
IPv6 resources they have in favor of preserving their LRSA fee increase
protection.

Do we really want to create an even bigger economic incentive to not only avoid
implementing IPv6, but to reverse some of the deployments that have already
been made?

>> 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. 

Until those LRSA holders need IPv6.

>> 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. 

And here’s where the real rub comes in… If you want to keep your
LRSA fee protection on your LRSA holdings, you get double-billed.

>>>     * 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. 

So consider that same strain absolutely applies to every LRSA holder
that also holds RSA resources due to the double-billing issue described
above.

Owen


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