[arin-ppml] {Spam?} Re: Open Letter Regarding 650% Rate-Hike for Legacy Users

[John Curran]

On 18 Sep 2021, at 11:05 PM, Owen DeLong <owen at delong.com> wrote:
> ...
> We’re taking about the fact that if you’re an end user, this latest fee hike is pretty abominable, while it’s a pretty nice subsidy for most LIRs paid for on the backs of the end users.

Saying “if you’re an end user, this latest fee hike is pretty abominable” conveniently ignores the fact that the fees go down for more than 3000 of the smallest end-users organizations as a result of the change. 

>> You can assert that ARIN's costs are predominantly the result of “LIRs” but that doesn’t reflect reality – many of our services and functions are equivalent for an entire address block and only a small set of them are related to subdelegation functions.   
> 
> IRR
> RPKI
> SWIP/RDAP/WHOIS
> RDNS
> Frequency of updates
> Frequency of additional requests/transfers/etc.
> 
> are all impacted more by LIRs than by end users.

Quite possibly, but it is also true that organizations that have larger total holdings result in more costs than those with smaller holdings – something that the prior end-user fees did not reflect.

> On the other hand, there’s also the fact that the LIRs are (generally) using their addresses directly for profit (i.e. their business _IS_ (at least in part) providing IP addresses to their customers). Essentially, they are reselling RIR services. 

In the ARIN region, LIRs provide connectivity services and the registry services are yet another cost in operating a network.  ARIN doesn’t provide connectivity services, and customers don’t go to Internet service providers because they view them as “resellers of ARIN services” but rather to obtain Internet services.  

> What you’ve done here, is to make everyone pay the same (within any given resource category ...

Correct - everyone pays the same for a given service category,  and these fees double for every 4x increase in total number resource holdings.   Customers can utilize the registry services they wish (RPKI, IRR, etc.) or not based on their perceived need and value without ARIN telling them how ARIN thinks their operation represents as a business.    A fee schedule that ignores the size of total resource holdings (as the end-user schedule was) is not fair nor is one that is linear to number of IP addresses represented by the registry entries.

>> Furthermore, there are costs that ARIN incurs as a result of customers that have no relation at all to the customers individual utilization of services or their choice to subdelegate, but still must be recovered (e.g. costs of responding to customers on mailing lists…)
> 
> If the costs of responding to members on mailing lists is a significant fraction of the ARIN budget, something has gone horribly wrong somewhere.

It appears to be just select members heavily utilizing the feature, so hopefully doesn’t add up to a significant fraction - however, the imputed costs must still be recovered and do not correspond to individual utilization of registry services or their choice to subdelegate.   i.e., It is inherent that cross-subsidization occurs with any fee schedule and all ARIN can do is have a clear and fair methodology for cost-recovery that is used for all customers. 

Thanks,
/John

John Curran
President and CEO
American Registry for Internet Numbers