[arin-discuss] Suggestion 2010.1 -- Initial Fee Waiver for IPv6 assignments to LRSA signatories

[John Curran]

On Feb 5, 2010, at 9:23 AM, Bob Atkins wrote:

John,

If I may interject. Your statement:

 '...whereas the effort to process a request for an additional IPv4 or IPv6 allocation can be very, very large, depending on the size of the previous allocation and organization of the request supporting materials.'

Is way over the top in regards to IPv6 allocations. The cost for an IPv6 allocation is about as close to $0 as one can get from a management standpoint. The sheer magnitude of available IPv6 address space is such that if all you had was an automated website without any form of controls - we would all be long dead before even a small portion of the IPv6 address space had been delegated - even if you had practically every person on planet earth applying for space.

For initial allocations, I agree 100%.  The criteria for an *initial* IPv6
allocation are quite modest, and hence it should relatively simply to
process and assign.

Generally, I am pleased with the IPv6 allocation fees being waived currently - it is quite simply why we applied for an IPv6 block. However, when I look at what is being proposed for IPv6 address charges - they are outrageous when you take into consideration that IPv6 is a virtually unlimited resource. IPv6 is a license for ARIN to print money. We are all going to be operating with IPv4 and IPv6 address space for a long time - that very fact will substantially increase ARIN's revenue based on the current fee structure. As a small ISP I find this very fact very troubling. Just as the market is eating itself alive from competitive pressure - when we must spend more in ARIN fees, equipment and training to deploy IPv6 and it will be virtually impossible to for us to recover any additional revenue from the use and delegation (to our customers) of IPv6 space. ARIN is maintaining what I call an IPv4 scarcity fee structure for IPv6 space which is totally at odds with the monumental amount of address space that is available.

Given the size of the IPv6 allocations, and present need-basis
requirements that must be assessed before an *additional*
allocation, it is quite likely that an ISP that comes in with an
*additional* allocation request would presently need to supply
a very significant amount of documentation that would need
to be reviewed.   I'm not saying this is "good" or "bad", but
simply reflects what actions ARIN will need to take based on
present policy.  If this is recovered via ongoing fee schedule,
then everyone will pay their share regardless of whether they
make additional IPv6 requests or not.  If it is transaction-based,
then just the party asking for the additional block will be paying
for those costs.

IPv6 fees for a /32 should be about $100/year - at most! Larger blocks could be sold on an economy of scale basis rather than a linear multiplier of the cost of a /32 block. The entire process should be fully automated - requiring minimal support staff. An even better solution would be to create some competition in the IPv6 address management arena by allowing the existence of multiple IPv6 registrars in the same way that is done for domain names.

One of the reasons that ARIN is investing significantly
in automation is precisely to aim for lower costs (and
hence lower fees) for those items which can be
automated. The current roadmap is available online
here: <https://www.arin.net/knowledge/roadmap.html>
Automation of maintenance will go far in reducing the
ongoing costs and allowing fee schedules which meet
expectations of the community.

/John

John Curran
President and CEO
ARIN
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