[ARIN-consult] Consultation on ARIN Fees on January of 2022
Lokkak
risner at lokkak.com
Tue May 11 14:34:54 EDT 2021
Thank you for your reply.
> To be clear, ARIN operates quite a few services (including publication
> of the registry via Whois and RADP, reverse DNS services, IRR and RPKI
> services) which benefits all customers even when customers are not
> making requests for changes or additional resource
I entirely agree, there are a number of services. Most of those are
directly related to the total number of IP addresses held.
My thinking is to not pick and choose, but there seems to be a
disproportionatly higher portion of the costs placed on the smaller
entities.
As a thought experiment, I pulled a full BGP feed today, did some
calculations to find the total number of routed IP addresses.
If we use a theretical group of 200 entities classified as 3X-Small,
they pay 167 times as much as the cost of the budget divided by the
total routed space. See the photo for more detail and I’ll happily
share the excel sheet if you wish to check my math.
> There may be some confusion here, since the proposed fee change does
> exactly what you ask above - it moves “legacy resource holders to
> the RSP Fee Schedule with the annual cap of total maintenance fees
> increasing $25 per year”
Apologies, I did a poor job with that message. I simply copied the
proposed changes and put my thoughts below.
Put differently, the smaller you are the more your fees contribute to
ARIN’s operating budget. It would be better if there was a flat fee
(say $125) to be a member, and the remaining amount is based on your
share of the adress space you have in the system.
For me with as a 2X-Small, in my suggestion, I’d pay $125 + 1,024 /
4,007,931,638 (routed blocks) * $23,507,000 (budget) = $6.00 or $131.
I have my own reverse DNS (in-addr.arpa. points to my DNS), I’ve only
made a couple requests in 4 years, and I’m not inclined to make
material changes for the next 10 years. However, I’ll see my costs
rise 300% in that decade on a resource that will decrease in value
(becoming more “retro computing”) at the same time.
This line of thinking is why I feel increasing the per change type fees
(such as OrgCreate, OrgRecovery, and Transfer) is an excellent way of
covering operating costs while minimizing costs for small entities with
few IPs and rare support cases.
Risner
On 10 May 2021, at 12:31, John Curran wrote:
> On 10 May 2021, at 10:14 AM, Lokkak
> <risner at lokkak.com<mailto:risner at lokkak.com>> wrote:
>
> This is coming from a perspective of a legacy holder, with an ASN, but
> no IPv6 address and entirely no desire to obtain IPv6 addresses.
>
> James -
>
> Thanks for the taking the time to respond to the consultation - your
> perspective is quite helpful.
>
> I have /22 of legacy address space, and I plan to maintain them until
> such time as they are no longer routable or simply niche of
> "retro-computing” routing.
>
> I’ll examine the changes one by one, starting with the transition:
> Transitioning End Users from annual per-resource maintenance fees to
> the RSP (Registration Services Plan) Fee Schedule
> I’d rather not have to migrate the the normal agreement. The
> included IPv6 Block Size has zero value to me. In 2017, my blocks were
> held with my ISP. I had to sign the LRSA 4.0 to move them into my
> control when that ISP closed. I don’t anticipate needing any changes
> or insuring any additional resources of ARIN. So the yearly fee of
> $125 should handle the limited labor cost my registration has for
> ARIN.
>
> To be clear, ARIN operates quite a few services (including publication
> of the registry via Whois and RADP, reverse DNS services, IRR and RPKI
> services) which benefits all customers even when customers are not
> making requests for changes or additional resources. After the
> extensive fee consultation that was held in 2014 and 2015, the
> decision was made to recover these costs in some proportion to the
> number resources held, as the benefit derived by those in the
> community is proportional to their resources held.
>
> We could lower base fees and charge separately for services that are
> optional but reflect best practices (e.g. this includes not only IPv6,
> but IRR and RPKI) but that doesn’t comport with our mission to
> support and advance the operation of the Internet - we’d effectively
> be creating a disincentive for network operator deployment of
> practices that many others simply consider good manners (e.g. MANRS -
> https://www.manrs.org/isps/)
>
> 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)
> For me, the yearly increase in maintenance doesn’t offer me more
> value nor help reduce ARIN’s costs. The costs for provide my support
> is minimal. It seems to be assuming everyone is taking advantage of
> IPv6 resources and generating additional ARIN support requirements.
>
> Providing a temporary IPv6 fee waiver for organizations in the
> 3X-Small category that desire a larger address block
> I’d rather see this feature removed and replaced with transitioning
> legacy resource holders to the RSP Fee Schedule with the annual cap of
> total maintenance fees increasing $25 per year. A pure legacy holder
> shouldn’t need to see fees increased, if they are not using IPv6
> addresses.
>
> There may be some confusion here, since the proposed fee change does
> exactly what you ask above - it moves “legacy resource holders to
> the RSP Fee Schedule with the annual cap of total maintenance fees
> increasing $25 per year”
>
> Note that this fee consultation results in no change for you, as you
> have /22 worth of direct allocations and an ASN, and would be invoiced
> today as an 2X-Small (at $500/year) if it were not for the legacy
> maintenance fee cap. Because of the cap you are invoiced $125 per
> year, and in 2022, you will pay $150 (again with the cap increasing
> $25 per year until you are eventually paying the same as all other
> 2X-Small ARIN customers.
>
> Implementing a $100 fee for OrgCreate and OrgRecovery transactions
> I believe this is an excellent way to recover costs of ARIN services
> for legacy holders.
>
> Increasing the transfer processing fee to $500
> This is also an excellent way to recover costs. I seem to remember in
> 2017, there was a great deal of effort on my part to effect the
> transfer. The $500 seems a good initial cost, but if that fee
> doesn’t cover the entire costs incurred by ARIN the fee should be
> sufficient to cover the costs of the work.
>
> Acknowledged, and very helpful to hear.
>
> Thanks again!
> /John
>
> John Curran
> President and CEO
> American Registry for Internet Numbers
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