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

Owen DeLong owen at delong.com
Fri Sep 17 23:40:26 EDT 2021

> On Sep 17, 2021, at 20:28 , David Farmer <farmer at umn.edu> wrote:
> On Fri, Sep 17, 2021 at 8:26 PM Owen DeLong <owen at delong.com <mailto:owen at delong.com>> wrote:
>> On Sep 17, 2021, at 10:57 , David Farmer via ARIN-PPML <arin-ppml at arin.net <mailto:arin-ppml at arin.net>> wrote:
>> The lines between what is an end-user and what is an ISP are getting very blurry these days. Is there really a difference between a data center, a university campus network, an enterprise network, and a small ISP each with a /20? 
> The use of the term ISP is what makes them blurry… s/ISP/LIR/ and it gets a lot simpler.
> Are you running an IP registry where you assign and/or allocate addresses to external downstream organizations? YES-> LIR… NO-> End User.
> Pretty much that simple.
> It ain’t really that simple, I wish it was.
> So some small ISPs, especially WISPs, may not actually SWIP any customers, because they don't assign any customers a /29, they just DHCP individual addresses to customers, or they may even NAT their customers. Are they an end-user since they don't SWIP, or an LIR because they are an ISP and sell connectivity?

Why not let them choose? They don’t really get any benefit from being an LIR member and since they aren’t running a local registry even though they are an ISP, why force them into the LIR category?

> Data centers, run similarly, some do SWIPs and some don’t. Why is it fair the data center that SWIPs gets one rate and the one that doesn’t gets a lower rate, sometimes an order of magnitude lower? They mostly are in the same business, and both usually sell connectivity, why different rates?

If they are allocating more than a /29 to any fo their customers they should be doing SWIPs. If they are not an LIR (not running a registry), then why should we care? Why not let them choose to be an end-user?

> Why should an enterprise with a few thousand employees get one rate and an ISP with the same number of customers have a much higher rate? Are there networks that much different?  Furthermore, an enterprise with a few thousand employees probably has many times the revenue, than the ISP with the same numbers of customers. 

I didn’t say they should. I said that a company which is operating as an LIR (regardless of whether they are an ISP or not) should be categorized as an LIR.

Why should I, as a private organization that is not deriving revenue directly from my IP Addresses pay a higher fee than a small WISP, even though they have 256 times as much IPv6 space as I do?

Why should an organization that has LRSA and RSA resources be double billed when an organization that is LRSA only or RSA only is not?

> And, you’ve been advocating for address leasing lately, so LIRs/ISPs, and maybe data centers, get to monetize their addresses, but enterprises can’t? The more addresses are monetized the blurrier the lines get. 

I would have no problem with that state of affairs, frankly, but even if we went completely as I’ve suggested (LIRs, including leasing) with a higher fee than end-users, anyone can monetize their addresses by selling them.

If you want to monetize your addresses and keep them, then yes, IMHO, since you are directly receiving a monetary benefit from holding the addresses, you should be paying more to ARIN than those who are not monetizing their addresses.

I’ll point out that by definition, ISPs and other forms of LIRs (yes, including leasing) are monetizing their addresses in one way or another, while the vast majority of those who could qualify as end-users (except at the very smallest scale of ISPs as you mentioned) are not.

Datacenter are an odd duck, but the ones that are running any significant network service to their customers probably need to SWIP and thus become LIRs. The others aren’t really monetizing addresses, so again, no problem.

> Further, I’m not sure there ever was that much of a difference in the burden on ARIN, between ISPs and similar sized end-users.

We can agree to disagree, it won’t be the first time.

> Personally, my biggest regret is ARIN didn’t give end-users more than a full years notice to ensure the increases could have been properly put into budgets, and maybe a multi-year phase-in for the largest increases.

Meh… My biggest regret is that at the price ARIN is now charging, I may have to abandon my /48 and go back to v4 only to get rid of the double-billing and limit the rate at which my fees increase.

> Nevertheless, it really isn’t as simple as you want to make it.

I think it still is… I’ll note that in every rebuttal, you stuck to the term ISP associated with LIR and I reiterate that that’s where the confusion and complication is coming from.

I’m absolutely willing to accept that some forms of ISP are not actually LIRs and allow them to operate as end users where it suits them.

I think the term ISP is a historical error that made sense once upon a time in a world where ISP and LIR were virtually synonymous. Today, that is no longer the case and the term LIR makes much more sense as the dividing line in fee structure.


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