[arin-ppml] New IPv4 Transfer policy

Owen DeLong owen at delong.com
Tue May 10 15:32:45 EDT 2011

> The fee structure is, fundamentally, based on the notion that a commercial money-making LIR should pay more than something like a public
> university even though they may consume fewer IPv4 addresses.
This simply isn't true. The vast majority of IP End-User resource
holders are for profit companies and I believe that the fee structure
was built with this knowledge.

The inherent assumptions in the fee structure, IMHO, are:

	+	ISPs consume more ARIN time and resources
		dealing with reassignment issues, more frequent
		requests, and more complex issues requiring greater
		staff review of their applications.

	+	ISPs get automatic voting membership in ARIN as
		part of their subscriber membership.

	+	ISPs pay fees based on their peak annual growth
		rate. They do not pay per-request fees.

	+	End users, by contrast tend to be much more stable,
		often acquiring an amount of resources once and
		then staying static (from an ARIN perspective) for
		several years thereafter. As such, a per-request
		fee for processing with a low annual maintenance
		fee makes more sense. Most end users choose not
		to participate in ARIN as members, but, those that do
		have the option for an additional fee.

> Thus it is very irritating when a commercial entity like Microsoft
> appears to get off scott free without making any kind of additional
> compensation to ARIN for enabling it to essentially make a ton more
> money than it's competitors.
Anyone who knows me will vouch for the fact that I will jump at
any opportunity to cry fowl on virtually any Micr0$0ft action which
warrants it. I expect to be leaving the Skype user community shortly
based on today's announcement, for example. I have a long history
of disdain for said convicted felon and their business practices.

However, I just don't see the issue here. They are paying the same
fee as any other end-user organization such as IBM, Apple,
Chevron, etc.

If they plan to use these addresses for reassignment as an LIR,
then, yes, there might be an issue, but, I haven't yet seen any
evidence that this is the case.

There are lots of managed hosting companies and other such
companies that use addresses to number their customer resources,
but, still operate as end-users under ARIN policy because they
retain control of the address space and do not reassign it
in whois.

> Do we really want an Internet with a few large LIRs and all the
> smaller ones gone out of business?  Because that is what the ARIN
> fee structure encourages.
I'm not seeing how this is the case.

In fact, the ARIN fee structure has not posed any meaningful
impediment to any of the small ISPs I have worked for. When
I joined HE, for example, we were in the Small fee category.
Today, less than two years later, we are in the Large category.
When I explained the fee issue to my management, it was
regarded as a "no-brainer" to pay the additional fees to get
the address space we needed to grow our business.
> There are more inequities between a large LIR and a small LIR.
I would agree with you if the fees were based on total size.
They are not. They are based on consumption rate.


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