[arin-discuss] SPAM-WARN:Re: [ppml] Counsel statement on Legacyassignments?(fwd)

[Michael Thomas - Mathbox]

Owen,

> -----Original Message-----
> From: Owen DeLong [mailto:owen at delong.com] 
> Sent: Friday, October 05, 2007 8:39 PM
> To: Michael Thomas - Mathbox
> Cc: arin-discuss at arin.net
> Subject: SPAM-WARN:Re: [arin-discuss] [ppml] Counsel 
> statement on Legacyassignments?(fwd)
> 
> >
> > 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.

No problem. Please accept my apologies in advance for all of the errors and
lame arguments that I advance.

> 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.

Hopefully, your argument above is the cost to ARIN to process and maintain
the allocation. Without a working experience with subscribers, I have no
facts to leverage, but would tend to agree that overall, larger subscribers
are probably more efficent subscribers. If in fact, smaller subscribers are
so inept as to cause that much effort to process an allocation, then perhaps
ARIN should have a per allocation fee. I do have difficulty swallowing that
one though. Realistically, if ARIN employees are overworked processing those
inefficent subscriber allocations, I think ARIN has the monetary resources
to hire additional help.

However, ARIN's cost to process and maintain the alllocation is not the only
consideration. The goal of all allocations is the IP address. That is so
significant, that ARIN measures SUBSCRIBER MEMBERSHIP DUES on the size the
allocation. By that measure, the pricing 

> 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

With the current requirements to get an initial allocation, that is a direct
result of ARIN allocation policy. This is the amount for which you qualify.
When you have used that come back again. That is not the fault of the
subscriber. That is ARIN policy.

> 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.

So, you see smaller subscribers as inept because they haven't learned the
ropes yet? Therefore, ARIN should increase relative cost of SUBSCRIBER
MEMBERSHIP DUES and create a barrier to entry rather than fostering and
encouraging new members?

> 
> 
> > 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

And as you have indicated, those large subscribers do know how to document
and substantiate those requests.

> 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.

I neither assumed nor suggested that staff time was linear. I may not have
clearly articulated my objection. I was reponding to a comparison of
processing effort for an initial small allocation by an ignorant (with out
knowledge) applicant to an apt applicant of a larger allocation. I was
suggesting that the impact on the resource pool of processing and even
reprocessing up to 15 times, that small _initial_ allocation was less
dramatic than processing those well documented and substantiated large
subscriber requests.

> 
> 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.

Hmmm.

> 
> > 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.

Right out of the gate, you assume so much. In fact, you assume everything.
You have with absolutely no facts. You assume, simply because I did not
apply for another allocation, that I have violated a "6 month supply" rule.
Apparently, no other outcome is possible. How about the simplist one? Got
that allocation; used it up; don't need anymore just yet. Lets try another
one. Multi-homed. Demonstrated efficent usage of a /23. Need 64 more IP
right now. Get an initial allocation of a /22. Took awhile to demonstrate
efficient usage of a /23. Needed more, but whoooohooo, its going to take
awhile to use up the rest of that allocation. Those people getting small
initial allocations are so lucky that ARIN does not penalize them for lack
of efficient usage aren't they?

> 
> > 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

One of the resources that ARIN manages and the point of this discussion is
the IP address. ARIN measures SUBSCRIBER MEMBERSHIP DUES by the IP address.
For those required to pay SUBSCRIBER MEMBERSHIP DUES to get IP resources,
the prices range from a /22 (a valid ARIN allocation unit) at a cost of
$1.22 per IP address to a /13 at $.035 per IP address. And by the way, if
you are large enough to warrant a /13 and need another /13. that one is
free.

ARIN IP address costs are not fair or equitable. ARIN, the non-profit and
resource steward, gains nothing by providing resources at multi-tiered
pricing levels, but does establish artificial barriers and promotes an
anti-competitive environment. So far, none of your arguments have convinced
me to think otherwise.

Although I am hoping it is not true, you have almost convinced me that you
believe small, initial, allocation subscribers are ignorant, inept, and a
troublesome bother to ARIN.

Michael Thomas
Mathbox
978-683-6718
1-877-MATHBOX (Toll Free)