[arin-discuss] tweak to proposed fee schedule

[Michael Sinatra]

Hi,

Currently there is a discussion going on over on ppml@ regarding policy
2013-3, which is largely being driven by an incentive issue with ARIN's
proposed fee schedule.  Specifically, the proposed fee schedule allows
for very small ISPs to fit in the "XX-small" category.  However, the
current minimum allocation for an ISP is a /36 (with a /32 being the
"standard" allocation), which does not allow a very small ISP to fit in
the XX-small category.

See the tables here for more info:

https://www.arin.net/fees/pending_fee_schedule.html

Because of this, concern has been expressed that this creates a
disincentive for small ISPs to adopt IPv6.  A policy proposal (2013-3)
has been developed that allows small ISPs to receive allocations as
small as /40s, while still reserving indefinitely a /32 for the ISP,
some or all of which the ISP can request at any time and without
justification.

However, there are some operational issues that arise from this use of
number policy to patch an issue with the fee schedule; these issues have
been discussed at length on PPML, and I refer the reader to the archive
of that discussion.  Briefly summarized:

o It results in a messy addressing plan, where the ISP is forced to fit
into a small corner of the potential space it has available to it.
This, in turn leads to two consequences:

o Customers will receive sub-standard reassignments as the ISP becomes
increasingly parsimonious with address space.
o As the allocation grows toward the /32 boundary, it becomes less
likely that the ISP will be able to have internally aggregable routing,
and this may make it more likely that the ISP won't re-aggregate its
space as it increases the size of its allocation over time, *even* if
that space is from a single aggregable /32.

I'd like to propose a tweak to the proposed fee schedule as follows:

"ISPs which have IPv4 resources and an IPv6 allocation of exactly /32
will have their fees calculated from the fee schedule based only on
their IPv4 allocation.  All allocation sizes other than IPv6 /32 will be
calculated from the fee schedule based on the greater of their IPv4 or
IPv6 allocation."

This only affects ISPs whose IPv4 allocations are in the X-small or
XX-small range *and* who have a /32 allocation.  ISPs and end sites with
allocations/assignments in the small or greater category will still pay
the greater of their IPv4/IPv6 allocation-category fee.

It's revenue-neutral with respect to the pending fee schedule, combined
with proposal 2013-3 because that proposal calls for the reservation of
the /32 for that ISP anyway.  I believe this tweak still allows for a
sustainable revenue model for ARIN until such a time as ARIN ceases to
provide IPv4 services, at which point the fee schedule will likely need
to be revisited anyway.

I am interested in this community's thought on this tweak.  I realize
the fee schedule is always a contentious issue, and I am reluctant to
get into a general discussion of fees (for more general discussions,
please create a separate thread).  However, I would like to know if
there are specific issues or incentive problems with what I am proposing.

Note also that I have no stake in this issue; this fee tweak would not
impact myself nor my current or previous employers.

Michael Sinatra
Energy Sciences Network
LBNL/DOE Office of Science