[ARIN-consult] Consultation on ASN Fee Harmonization

[Steve Noble]

> On Jul 10, 2023, at 3:02 PM, John Curran <jcurran at arin.net> wrote:
> 
>> On Jul 10, 2023, at 2:28 PM, Steve Noble <snoble at sonn.com> wrote:
>> ...
>> 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? 
> 
> Steve – 
> 
> The ~6800 are ASN-Only holders (no IPv4 or IPv6 resources) with a single ASN.    The 313 are ASN-Only holders (no IPv4 or IPv6 resources) who have multiple ASNs. 
> 

John -
You did not answer the question, the 6800 is approximate, ARIN must know the actual number.

>> 2. How many single ASN holding organizations are members of this mailing list?
> 
> Unknown.  The arin-consult mailing list is open to all interested parties who comply the Mailing List AUP and ARIN Participants Expected Standards of Behavior – these are not correlated to ASN holders.

This is concerning since 6800+ organizations would be affected and may not know so since they have not been members and would not be part of the members mailing list, etc.

> 
>> 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?
> 
> That’s not quite correct - ASN Only Holders represent 30% of total customers [where total customers are Service + General + ASN Only.]
> 
> (If one adds uncontracted legacy customers to that total, ASN-Only holders represent only ~18% of total customers.)

John, I am talking about the affected parties, the ~7113 ASN-Only holders, 95% of them will be affected negatively.  What percentage they are of the total number of customers is moot as the document I point to clearly states :

"● Transitioned all customers with IPv4 or IPv6 number resources to the same RSP (Registration Services Plan) Fee Schedule:”

This does not cover ASN only holders.  If ASN only holders were included in the not affected list and chart that would be incorrect as they were not included in the list of customers this was positioned as being.

> 
>> 5. Of the impacted organizations, how many pay for membership separately?
> 
> None, as paid membership was removed as part of the 2022 fee schedule change. This change (ASN Fee Harmonization proposal) in fact provides Service Member status to all ASN holders. 

So accordingly, zero ASN only organizations applied to be members, I don’t see how forcing them to pay more for something that they never applied for is a valid benefit.

> 
>> 6. Of the impacted organizations, how many have requested IPv4 resources? 
> 
> Indeterminate, as it is often possible to request resources without supplying ASN holding information and thus correlated.  

ARIN should know how many ASN only members requested IP addresses at least on an org level.  If the ASN belongs to a different organization, that would not apply here as we are talking about organizations that only hold ASNs.

> 
>> 7. What is the overlap of single ASN holding organizations paying for membership and requesting IP space (two items claimed in the benefit section).
> 
> No one is paying for ARIN Membership since the 2022 fee schedule change 
> 
> (All organizations holding IP number resources under agreement have had service member status since Jan 2022, and can request General Member status if they wish to participate in voting & ARIN governance discussions). 
> 
> ASN-Only holders will now have Service Member status as part of the ASN Fee Harmonization proposal AND will be able to request corresponding IPv4 and IPv6 space if they choose with no change in fee category. 

But according to above you have provided information that zero ASN only organizations that have done this so far, so ARIN is forcing ~6800 organizations to pay more for a benefit that they have not requested.

> 
>> 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?
> 
> They would all qualify for IPv4 or IPv6 if they are running a network and using their ASN to run BGP.   It probably goes without saying that there is more than enough IPv6 resources for all ASN-only customers...
> 
> For IPv4 resources, many would end up on the IPv4 waiting list today, but note that for those who wish to run IPv6, there is enough 4.10 transition IPv4 space (~14.5k /24s are available under 4.10 as of June 2023) to theoretically issue 4.10 IPv4 transition blocks to all of the ASN-Only holders.

I think that is a false equivalence comparing transition space to available space. For example I applied for my ASN 23 years ago, IPv4 space was much easier to get.  Had you charged the same fee whether I had space or not, I would have applied for space. 

> 
>> 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.
> 
> This change provides for recovering costs more equitably for services to across the ARIN customer base, 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.

John - How much does it cost to provide service to an ASN only holder?  What actual, tangible benefit do they get with this change?  The affected organizations could have asked to be members or for IP space the entire time.  There is no upside to this that has been documented and it’s certainly all negative from my position.

> 
> In addition to bringing all ARIN customers into a unified, equitable fee schedule, the ASN Fee harmonization will facilitate ASN-only resource holders obtaining IPv4 and/or IPv6 resources if they choose to do so. 

And to this point they should be able to choose, If an ASN only organizations wants resources or to be a member, they can pay more.  If they want to stay how they are they can stay how they are.  Forcing ASN only organizations to foot the bill for those who have or want more is not equitable.
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