[ARIN-consult] Consultation on ASN Fee Harmonization

[Steve Noble]

Greetings.

In-line

On Fri, Jun 30, 2023, 9:42 AM ARIN <info at arin.net <mailto:info at arin.net>> wrote:
ARIN is consulting with the community (https://www.arin.net/participate/community/acsp/consultations/2023/2023-3/ <https://www.arin.net/participate/community/acsp/consultations/2023/2023-3/>) about harmonizing annual registration services fees for Autonomous System Numbers (ASNs) so that they will be included in the Registration Services Plan (RSP) fee schedule beginning 1 January 2024. This change will have the benefit of recovering costs more equitably for services to ASN-only holders, with the added benefit of making ASN-only customers ARIN Service Members, thus providing them with the opportunity to become General Members and participate in ARIN governance if they so choose. This change will bring all ARIN customers into a unified, equitable fee schedule.

I am vehemently against this idea as all of the "benefits" are things that the 6800+ single ASN holder (affected parties) could opt in to if they felt that they needed them.  The fee is already excessive and disproportionate for a single resource that requires little to no maintenance or support.

I also note that this does not appear to be sent directly to the affected parties themselves. How many of the affected parties are subscribed to this list?  Having been a fee paying non member of ARIN for over 23 years, iI think it’s important to state how many of us are represented here.


In 2022, ARIN transitioned end user customers to the RSP fee schedule based on total IPv4 and IPv6 resources held, to ensure costs were distributed in an equitable manner by eliminating the fee differentiation between ISP and end user organizations. Now ARIN is seeking community feedback on a plan to complete the fee harmonization process by transitioning ASNs to the RSP Fee Schedule.

Proposed Fee Harmonization (all fees in USD)

- Organizations holding 1-3 ASNs will be categorized as 3X-Small, with an annual fee of $250.
- Organizations holding 4-15 ASNs will be categorized as 2X-Small, with an annual fee of $500.
- Organizations holding 16-63 ASNs will be categorized as X-Small, with an annual fee of $1000.
- Organizations holding 64-255 ASNs will be categorized as Small, with an annual fee of $2000.
- Organizations holding 256+ ASNs will be categorized as Medium, with an annual fee of $4000.

Based on financial modeling using May 2023 revenue and customer data, there will be a negligible effect on our existing RSP customers due to the proposed fee change, with only 15 existing organizations holding sufficient ASNs where they will transition to a higher fee tier. Among them, two are expected to transition from the 3X/2X-Small service category to the X-Small bracket, while 13 will move from the 3X-Small to the 2X-Small service category. This shift is attributed to changes in fee size classifications based on the balance of ASNs compared to the IPv4 and IPv6 number resources they currently possess.  

Comparatively, for customers who solely hold ASNs, approximately 313 will experience a decrease in their total fees. With the proposed change, they will no longer be charged annual fees for each individual ASN, resulting in savings of between $50 USD to $1,750 USD for these customers. Conversely, the estimated 6,800 single ASN holders will experience an increase in their fees of $100 USD when they are brought under the RSP fee schedule, now falling under the 3X-Small fee service category. While this is a substantial increase on a percentage basis, it more accurately reflects the basic costs of serving an organization with registry services and provides those customers with the opportunity to obtain additional ASN’s, IPv4, and/or IPv6 resources with no change in their fee category.


I have a lot of questions:

1. The above paragraph states that there are approximately 6800 organizations holding a single ASN and more specifically 313 with multiple ASNs, what is the actual number of organizations with a single ASN and no other resources? 

2. How many single ASN holding organizations are members of this mailing list?

3. Based on the maximum savings, the largest only ASN holder has 15 ASNs (150*15 - 1750 = 500) and the smallest multiple ASN holder has 2 (300 - 50 =250).  What is the breakdown within the 313 affected parties of the # of ASNs they hold?

4. The customer impact is significantly unbalanced where over 95% of the organizations fees increase vs the 2021 changes (https://www.arin.net/participate/meetings/ARIN49/materials/426_feemembership.pdf <https://www.arin.net/participate/meetings/ARIN49/materials/426_feemembership.pdf> slide 7) where ~50% stayed the same. Why is this not clearly stated in the document?

5. Of the impacted organizations, how many pay for membership separately?

6. Of the impacted organizations, how many have requested IPv4 resources? 

7. What is the overlap of single ASN holding organizations paying for membership and requesting IP space (two items claimed in the benefit section).

8. For due diligence, based on the data ARIN has compiled, how many of those single ASN organizations would qualify for IPv4 resources and be approved and have them allocated within the billing period that this change would happen? Does ARIN have 6800 /24 IPv4 blocks available to allocate to the affected parties?

In summary, based on the information provided so far, I believe that raising prices for 6800+ organizations to slightly lower the cost burden of 313 is unfair and unreasonable. There has been no data provided to show what the cost of serving a single ASN organization is other than your aggregate groups showing that it is <=$15.

Btw I noticed while trying to research the membership fee information (https://www.arin.net/participate/oversight/membership/ <https://www.arin.net/participate/oversight/membership/>) the page has many broken links.  I don’t even see the current membership fee information on the latest fee page (https://www.arin.net/resources/fees/fee_schedule/) vs the 2018 page (https://www.arin.net/resources/fees/fee_schedule/2018_fee_schedule)

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