[arin-ppml] fee structure

Steven Ryerse SRyerse at eclipse-networks.com
Sun Mar 31 00:25:56 EDT 2013

John I do appreciate your comments below but as always they miss the overall point that I continually try to make.  The comments that I have made to this community since I joined it have mostly been big picture as were my comments earlier today.  As a CEO I've had to face big picture problems and make big picture decisions and I will continue to point out that there is a big picture problem whenever an allocation request is completely denied by ARIN.  (Like mine was for the Minimum sized IPv4 block.)

The big picture problem I keep pointing out can't be solved by a change to a policy or by removing a policy or even by adding several policies.  The problem I keep pointing out (over and over) is that every single policy that has any language in it that is used by ARIN's staff to deny an allocation request - for any reason other than the size of the allocation request does not match the size of the organization - needs to be changed or abandoned. 

Every single request should be filled with at least the "Minimum" size allocation and NONE should be turned flatly down with no allocation made!!!!!  This is because DENYING ALLOCATIONS is NOT the charter of ARIN and not ARIN's Mission as outlined in ARIN's Mission Statement.   

John, you have responded to me several times including in your comments today below that your policies reflect this community's wishes and that ARIN doesn't actually make the policies.  So, following that logic that means that if this community decides for example to support a policy change that completely stops IPv4 allocations to everyone because of say IPv4 depletion or any other reason, that would be OK with the leadership of ARIN because it is what this community wants.  I submit that such a policy to stop ALL IPv4 allocations would NOT be OK because it would be 100% against the charter of why ARIN was founded and the Mission it is supposed to operate under.  

I repeat what I said earlier today in my post:  ARIN's Mission is to ALLOCATE resources and it isn't to NOT ALLOCATE resources.  I would add to the end of that sentence "Even if it causes ARIN to run out of IPv4 addresses to allocate". 

I've seen many policy discussions just like the one that has been going on over the last several days which boil down to just how hard this community wants to make it to get resources. It was very clear during the discussions of the change in policy sought by some of the Canadian Cable companies that several folks in this community didn't want to give them more allocations because they thought the Cable companies were not using allocations efficiently enough.  Again in my opinion that is a totally arbitrary argument being used against them and it is just another excuse to NOT ALLOCATE.  I will repeat AGAIN that arbitrary excuses to NOT ALLOCATE are against ARIN's Mission!  They should be allocated resources based on their size - end of discussion. Their efficiency and how they used resources in the past is totally irrelevant to ARIN's Mission to ALLOCATE.  They shouldn't have to beg this community for resources to perform their Internet Mission.  They should be applauded for furthering the Internet which of course is part of ARIN's mission.  

My big picture observation is that all of these discussions are going down the road slowly but surely of DENYING ALL ALLOCATIONS of IPv4. This is why I don't (as you continue to suggest) try to fix a policy by offering a slight change to one - as the whole set of allocation policies needs to be largely abandoned and replaced with a few very simple to administrate policies that gage the size of the organization and match up the allocation to the size of the need - and then ALLOCATE.  IPv4 and IPv6 policies should be identical except for the obvious technical differences.  

At what point John, do you as CEO of ARIN along with your Board of Directors, use your leadership roles to help this community see the big picture that they are getting farther and farther away from the Mission of ARIN in the allocation policies that are being proposed and adopted - and urge this community to correct this?  Seems to me that is your fiduciary responsibility as Officers of ARIN.

-----Original Message-----
From: John Curran [mailto:jcurran at arin.net] 
Sent: Saturday, March 30, 2013 6:40 PM
To: Steven Ryerse
Cc: arin-ppml at arin.net
Subject: Re: [arin-ppml] fee structure

On Mar 30, 2013, at 2:42 PM, Steven Ryerse <SRyerse at eclipse-networks.com> wrote:

> Unfortunately it is somewhat rare to see comments from legacy holders in this forum even though I know a lot of them at least "listen" to postings here as I've had several make comments to me off-line over time.  I think comments from legacy holders should be aired in this forum as their comments would make these kinds of policy decisions better - even when philosophical issues come up like is happening in the current discussions.

Agreed.  If anyone has interest in how the registry for the region is operated, then I would strongly encourage them to speak up.  While we do have a mailing list specifically for members to address issues such as fees and services, the fact is that you can't have fair discussion about some items (such as equitable fees for membership) on a list of which includes only members.  The same obviously applies to number policy, which effects everyone in the registry and hence one of the reasons that we have always had the public policy mailing list open to all.

> In my humble opinion his most important point is that all of these rules are arbitrary.  If you stand back and look at all the quibbling going on about whether someone should be able to get a /40 or a /36 or a /32 or a /whatever - it is easy to see that "community" wishes to limit the assignment of IPv4 and even IPv6 resources for their purposes - whatever they may be.  All of these conversations boil down to how best to LIMIT IP resources!

As noted later in your email, "there should be NO LIMITS placed by ARIN other than a simple justification of the size of the requested block needed as we all obviously all don't need a /8." 

Presently, we've got some fairly straightforward IPv6 allocation policies for both ISPs and end-users, and no one is discussing putting _any_ restriction on issuing an /32 to ISPs... the question being discussed is whether we should allow them to request _less_ space (if that is what they desire) so that we can provide a lower associated fee ($500/yr) as well.  We can't move all ISPs to that number but would like to allow the smaller category and fees if it makes sense. We seem to have some folks who think that it would be a worthwhile change, and some who believe it will encourage some ISPs to economize their customer assignments to fit in the lower fees (which are more than half of what they would pay otherwise.)

None of this is "driven" by ARIN... At the end of the day, the policy as to whether ISPs can request a /40 (rather than /36 or /32) will be set by the community.  The Board has expressed willingness to have these lower fee categories (they approved the IPv6 /36 already and the change for /40 will be considered), but again, that's presuming that the community wants to set some policies which would allow an ISP to request _less_ IPv6 space than presently allowed today.

> I've said many times and I'll keep saying it as long as I can breathe that ARIN's mission is to ALLOCATE resources and not to find reasons NOT TO ALLOCATE resources.   IPv4 depletion being the justification be damned! 

I actually agree with that (personally), but despite what you may have heard to the contrary, I not make policy for the ARIN region; the community on this list does, based on lots of discussion against policy proposals that are actually submitted.  If you think that policy should be different, then submit a proposal which describes how and why it be changed.

> IPv4 depletion being the justification be damned!  The big elephant in 
> the room is that legacy holders are afraid of having their resources 
> (and thus their businesses and their missions) impacted by all of the 
> community policy discussions that are about somehow limiting resources 
> or increasing fees or whatever.  Who can blame them for taking the 
> stance that better to be cautious and not sign anything that might 
> give Arin any rights over them - just in case the "community" which is 
> by design unpredictable - decides to do something harmful.

Perfectly reasonable concern when it comes to fees, particularly given that the revised fee schedule does set legacy address holder fees to be the same as any other end-user.  However, I will also note that Legacy RSA (which many folks talk about but never seem to read) actually has some protections specifically regarding these concerns: <https://www.arin.net/resources/agreements/legacy_rsa.pdf>

"ARIN may increase the Legacy Maintenance Fee after December 31, 2012, provided  that (i) the Legacy Maintenance Fee cannot exceed the maintenance fee charged to  comparable non-legacy holders for the maintenance service as set forth in ARIN's  Standard Fee Schedule as posted on ARIN's Website for comparable number resources,  and (ii) ARIN must set these fees in an open and transparent manner through the  ARIN community consultation process."


"Whenever a transfer or additional IP address space is requested by Legacy Holder, 
 ARIN may review Legacy Holder's utilization of previously allocated or assigned
 number resources and other Services received from ARIN to determine if Legacy 
 Holder is complying with the Service Terms. Except as set forth in this Legacy 
 Agreement, (i) ARIN will take no action to reduce the Services currently provided 
 for Included Number Resources due to lack of utilization by the Legacy Holder, 
 and (ii) ARIN has no right to revoke any Included Number Resources under this 
 Legacy Agreement due to lack of utilization by Legacy Holder."

Legacy holders who enter into an LRSA are indeed bound contractually
to ARIN policies, but they also receive some fairly straightforward 
protections in the process.
>  My experience of applying for an IPv6 block in the Small Category and being approved one month, and applying and being denied for the current Minimum Size IPv4 block the next month - provides a real life illustration of just how arbitrary Arin's rules really are.  I should have been approved for both or rejected for both!

Actually, it simply proves that the IPv4 and IPv6 policies are different.  
If you want them the same, then you need to persuade your fellow service 
providers and end-users on this list to change them accordingly.

>  John said in his email to David Farmer yesterday "ARIN is here to serve the community, so the normal response to any request should be "Yes", unless there a clear reason (example, potential impacts to other parties) that something should be prohibited by policy".  Obviously since I was approved for IPv6 and denied for IPv4, Arin found a reason to say "No" to me rather than "Yes" for IPv4 because of some arbitrary policy stemming from IPv4 depletion concerns.  As I said IPv4 depletion be damned as it isn't Arin's Mission to NOT ALLOCATE even the Minimum block to a party with need.  
> ...
> There should be NO LIMITS placed by Arin other than a simple justification of the size of the requested block needed as we all obviously all don't need a /8. Then Arin should ALLOCATE for a reasonable cost that covers Arin's bills.  For the record I have no problem paying a to make sure Arin's reasonable bills are paid.  

That is good to know; it's also similar to the reasoning that has led to 
ARIN having 4 fee reductions since its inception; we need to only recover
reasonable amounts to cover our costs. 

> I'm sure I will get the obligatory email response from John about this email (which I do think is good) but then my comments again will be ignored by this community - and unfortunately all of the legacy holders will continue to be cautious and stay away as long as they can.  I applaud Mathew's attempt to contribute here and the sanity he is trying to provide!
> -1  This member is against the current changes as proposed because at least in part it further restricts ALLOCATION of resources which I believe to be against Arin's Mission.  

As we're presently discussing: 1) The new fee schedule (aka the "Pending Fee 
schedule) which the Board has adopted; 2) A potential change to the Pending 
Fee schedule to make the xx-small category include IPv6 address holders with
as large as a /40 IPv6 allocation; #) A change to policy [Draft ARIN-2013-3]
to allow ISPs to request as small as a /40 of IPv6 (presently limited to as 
low as a /36 of IPv6), and 4) A change to a policy [Draft ARIN-2013-2] which
would treat 3GPP networks in a manner similar to current cable providers for
purposes of showing utilization of past blocks when requesting additional
space, would it be possible for you to be just a bit more specific about
which "current changes as proposed" you are referring to above?


John Curran
President and CEO

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