[arin-discuss] [ppml] Counsel statement on Legacyassignments?(fwd)

[Owen DeLong]

>
> Owen,
>
> For several reasons, I honestly do not believe that your cost  
> allocation is
> accurate.
>
> 1. In another message unrelated to this one, you point out to  
> Jeremy that
> someone returning for another allocation does not pay separately  
> for each
> allocation.
>
Correct.  My cost allocation was based on the ASSIGNMENT fees, not
the Allocation fees.  Allocation fees are different.  Allocation fees  
are
not actually about IP addresses at all, except that the number of IP
addresses is used as a rough approximation for ARIN to determine
other related costs to providing membership services. I accept my
error and apologize for the confusion.

Allocation fees are actually SUBSCRIBER MEMBERSHIP DUES
for membership in the organization as a SUBSCRIBER MEMBER
and are based on the size of your subscription.  Beyond a certain
size subscriber, your fees do not increase because there is a
tendency for such large subscribers to have smaller increases in
costs with ARIN as their size increases.

The allocations between /24 and /16 in size tend to incrementally
increase the number of ARIN changes to RDNS and the number of
SWIP changes which need to be registered.  Assignments larger than
a /16 begin to have smaller incremental cost increases at ARIN because
the number of malformed SWIP requests submitted tends to go down,
the number of RDNS changes that need to be made by ARIN tend
to go down (ARIN points entire /16s and the ISP delegates the
multiple /24s), etc.


> 2. In the second and subsequent years of an allocation, one still  
> pays the
> entire fee. If your argument held water, the second and subsequent  
> year fees
> would be reduced by the application processing cost and would  
> reflect only
> the maintenance cost.
>
Right.  For that fee, you have covered the costs for two people's  
registration
fees for the semi-annual membership meetings, you have paid for the
operations of RDNS and WHOIS, the SWIP processing system, operations
of the PPML, and other mailing lists, your continued use of resources
at the Registration Services Help desk, should you need them, and
several other ancillary benefits of membership in the organization,
as well as a fee related to the proportion of space you need.

> 3. Comparing the time to review an intial /24, /23, /22, /21  
> allocation to a
> /14 or larger allocation as taking longer due to the applicant being
> unfamiliar with the process is questionable. The allocation of a  
> larger
> block should actually be scrutinized more heavily, because it  
> removes more
> resources from the available pool.
>
You are assuming that staff time is linear with level of scrutiny.   
That simply
isn't true.  I happen to know that staff is very thorough in their  
scrutiny of
each and every request.  However, a well documented request with the
appropriate data and supporting information which meets policy can be
very thoroughly scrutinized very quickly.  OTOH, a malformed request
which takes 15 tries back and forth before the applicant actually gets
all the right data together can take much longer and occupy many more
staff hours.  Additionally, requests which are submitted, then, modified
several times are subjected to additional scrutiny to prevent fraud.
This is reasonable.

The reason that, on average, larger requests take less staff time is  
because,
on average, larger requests are submitted by people who do this for a
living and know what documentation is required and can submit a
correct (or closer to correct) request with appropriate supporting  
documentation
on the first try.

> 4. If in fact the total cost is based on application costs and  
> maintenance
> costs, the fees would reflect that.
>
There are other factors (as outlined above) which go into the SUBSCRIBER
MEMBERSHIP DUES pricing.  However, I still think that it is a relatively
fair system and that you are not being unfairly charged.

> 5. I just paid my second annual fee. The cost was the same as last  
> year. I
> did not make any applications this year.
>
Right.  However, here's something to consider.  You didn't have any  
addresses
revoked even though your "6 month supply" lasted you well over 6 months.
You still haven't been actively penalized by ARIN for failing to meet  
the
policies in applying only for what you need for 6 months.

> 6. The fees are based on the total size of all allocations. You  
> have said
> so.
>
The fees are charged on the total size of the allocations because  
that is a
simplified yard stick which allows a fee structure that is easier to  
understand,
communicate, implement, and maintain.  There is a difference between the
way the fees are computed and the actual cost-basis of the fees which
is what I meant by what they are based on.  This abstraction is  
useful for
a number of reasons, but, it does mean that if you are an exception, you
may pay a bit less or a bit more than someone who is closer to the norm.


Owen