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

Owen DeLong owen at delong.com
Fri Sep 17 20:47:49 EDT 2021

Similarly, I have 4 records in the ARIN database… 3 are registered to me and covered by RSAs. One is thankfully effectively registered to me and not covered by an RSA.
I will discuss the three that are RSA’d here.

2620:0:930::/48 Registered in November, 1994 shows last updated in March, 2018. I don’t think this update was initiated by me. The previous update (when the ORG was
last updated goes back to Agust, 2013. I still can’t even be certain that update was initiated by me, but even if I’ve updated
the record every 8 years since inception, I have trouble believing that I’ve gotten $250/year worth of ARIN services specific to this resource. Unfortunately, because
ARIN forcibly bifurcated my organization without my consent when they switched from fee-per-org for end users to fee-per-resource (due to some accounting difficulty with
being able to handle a single ORG with different RSA terms on different resources). Now, with the forced-RSP change in the new fee schedule, this will be in addition
to my IPv4 fees, putting me at a disadvantage vs. most other members as I get double-billed instead of the MAX(v4,v6) fee category.

ARIN’s response is that I can consolidate if I’m willing to forego the fee cap built into my LRSA. They are not willing to fix the billing system or consolidate my v6 holdings
into my LRSA. The only real difference in terms between my RSA and LRSA at this point is the fee hike cap in the LRSA. Registered prior to ARIN inception and (much to my deep regret at this point) brought under the LRSA in November, 1994 (which ARIN now lists as
the registration date, a fallacy, it was originally registered well before that). This record was last updated in 2018, but I don’t think that update was initiated by me.
The last update to the alter-ego-ORG artificially created by ARIN for this resource (and my other LRSA record) is September, 2011. The creation date on the
artificial organization, amusingly, still reflects the actual registration date of the LRSA resources in February, 2009. Also registered prior to ARIN inception and (also to my deep regret at this point) brought under the LRSA in November, 1994. This record somehow
kept its original registration date (September, 1991). It was last updated in April, 2012.

All of these records have completely current data.

As you can see, I do not make significant or frequent updates (far less than even once per year).

My interactions with ARIN for these resources are (the vast majority of years) limited to:
	1.	Contact verification (one contact, one verification covers all resources).
	2.	Paying the bills (I get two bills courtesy of ARIN’s refusal to fix their accounting system. They have this nice perverse incentive
		where the problems with the accounting system allow them to double bill me.

When I signed the RSA, John Curran himself informed me that there was no financial penalty to doing so because the fee per organization
meant that I’d be paying for the IPv6 resources under LRSA anyway. Further, the promise was that my total LRSA related fees would not
increase by more than $25/year.

Both of these claims were made false when the board came up with the clever idea to charge per resource shortly thereafter.

Instead of my LRSA fees increasing from an effective $0 (My $100/year was going to my IPv6 costs which were elevated to $150
overnight in that process) to $25 on the following billing cycle, they increased to $125 and continued to go up $25/year ever since,
modulo the great LRSA fee reset a few years back due to ARIN not doing the $25/year increment right for several LRSA holders).

So instead of my fees increasing $25/year from $100/year to $125, $150, etc. They went instantaneously from $100 to
$275 and then continued to go up from there.

Instead of the no financial penalty for signing LRSA originally promised (though I admit I failed to get that part in writing), I’ve
been repeatedly faced with escalating costs for the LRSA, including the afore-mentioned double-billing.

I got an admonishment from ARIN’s lawyer for calling this a scam, so I won’t call it a scam here, but there is tremendous
similarity between what has happened and many other activities I would call a scam.


> On Sep 17, 2021, at 09:31 , Mark McDonald <markm at siteserver.com> wrote:
> John,
> 	I just came across your spreadsheet of fee increases.  It pretty much summarizes what I’ve been saying - this isn’t a neutral harmonization of fees, it’s a 20% rate hike on roughly 40% of ARIN’s customers that disproportionally affects ARIN’s smaller customers, with Large being the middle tier in ARIN’s fee schedule, while targeting end users that use a fraction of the services of an ISP.  In nearly 20 years we’ve opened 5 ticket and in all cases, chose to better optimize IP space rather than pull from a finite resource (IPv4 address space).  That works out to about $1000/ticket - does it really cost ARIN more than $1000 to respond to a ticket?
> 	It would be nice to show in that spreadsheet how many IP’s are represented in each Category - both RSP and End User.  My assumption, and I could be wrong, is that these fees are going towards users who are already paying 30-40x more than those utilizing the most resources.  The previously proposed $800/object almost seems like a bargain compared to what’s being proposed for us.  This isn’t about the money, it’s about the principal of what users ARIN is raising fees on.
> 	I’m curious as to who made/makes up ARIN’s Fee Structure Review Panel and why wasn’t outreach done back then?  I was sure notified from 3 different departments when ARIN blasted out fee increases of 650% so it seems capable of better communication.
> 	What should happen is ARIN truly engages it’s customers and if it needs 20% more revenue so badly, perhaps look at taking it from the companies that have profited most from the services you provide and who already pay a tiny fraction of what smaller users do for the resources (IPv4 addresses) they consume.
> 	I need to get back to vendor negotiations.  I’m trying to get Verisign to reduce our domain renewal rates by 99.61% because we only use their API and don’t consume even a tiny fraction of resources of what a retail customer does and they only discount our rates by like 8% - crazy right?!  They’re pushing back stating that domain names are a limited resource and we’re going to make a boat-load of money off of my proposal by buying nearly every domain at 3/10ths of 1% of their normal customer but they simply don’t understand the volume we’ll be able to bring.  I’ll keep you posted on how my negotiations go.
> -Mark
>> On Sep 17, 2021, at 4:36 AM, John Curran <jcurran at arin.net <mailto:jcurran at arin.net>> wrote:
>> On 17 Sep 2021, at 3:52 AM, hostmaster at uneedus.com <mailto:hostmaster at uneedus.com> wrote:
>>> Some have suggested the fee should not have a relationship to the number of addresses, but I strongly disagree.
>>> For the most part, the more addresses you have, the more SWIP transactions and reverse lookups and customer service transactions are going to take place, so it is quite proportional.  
>> Albert – 
>> This is incorrect – i.e. the assertion that ARIN’s costs are proportional to the span of address space represented by registry objects – and it is also likely beyond the possibility of physics (as noted below.)
>> Larger entities almost always have dedicated personal who knowledgable of ARIN and our processes – while they may make some additional customer services transactions (due to acquiring additional resources or using more advanced services), it would be highly unusual for any of them to make hundreds of more frequent customer service requests, let alone the thousands, or hundreds of thousands, that you suggest and would be necessary for ARIN to bear a proportional cost burden due to servicing such organizations. 
>> There are significant fixed costs of operating the registry and these fixed costs are predominately related to the number of organizations that must have billing relationships with ARIN and the number of resource entries in the registry – they are _not_ proportional in any manner to the size of the address space span represented by the registry objects.
>> Note – In 2014, the previously mentioned Fee Structure Review Panel looked at an approach that sought recover a fixed amount per registry object and use rather significant transactions fees to correspond more directly to the level of effort for recovering costs of registration service requests (aka Proposal #7 “Transaction Fee Proposal” in the previously referenced report.)  It was clear that such an approach would quite significantly penalize the smaller registry users, as it results in per registry object fees of more than $800 per object per year and larger  transaction fees. The fact of the matter is that ARIN’s present geometric registry fee scale burdens organizations with the largest number resource holdings far in excess of their imputed costs to ARIN, and while this is obvious, it was also felt to be overall reasonable because the _benefit_ obtained could also be deemed to be disproportionate. 
>> FYI,
>> /John
>> John Curran
>> President and CEO
>> American Registry for Internet Numbers
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