Re: [nanog] 2749 routes AT RISK - Re: TIMELY/IMPORTANT - Approximately 40

[Owen DeLong via NANOG <nanog () nanog org>]

> On Apr 7, 2022, at 03:21 , John Curran <jcurran () arin net> wrote:
>
> On 7 Apr 2022, at 1:05 AM, Owen DeLong via NANOG <nanog () nanog org <mailto:nanog () nanog org>> wrote:
> > > On Apr 5, 2022, at 15:04 , John Curran <jcurran () arin net <mailto:jcurran () arin net>> wrote:
> > > ...
> > > Correct - ARIN caps the total registry maintenance fees for legacy resource of those who do enter an RSA with ARIN 
> > > to $150/yr (the cap increasing $25/year) – the legacy cap only covers the fees for registration services for IPv4 
> > > number resources, so it must be billed separately and not part of a registration services plan that includes both 
> > > IPv4 and IPv6 resources. 
> > >
> > > You can consolidate to one relationship if you wish - and end up paying the very same registry fees as everyone 
> > > else – but then the legacy fee cap doesn’t apply because you’ve got IPv4 and IPv6 resources under the same service 
> > > plan.
> > >
> > > This is a case where no good deed goes unpunished - by providing a registry fee cap specifically for legacy 
> > > resource holders, it can sometimes lead to a financial disincentive for legacy holders to get IPv6 resources since 
> > > they would then end up paying the exact same fees as everyone else. 
> >
> > Well, I’m not as convinced as you clearly are that there are good deeds involved here.
> >
> > I proposed a number of ways in which ARIN could have preserved the fee cap for v4 and allowed LRSA recipients to pay 
> > MAX(v4Legacy,V6) vs. the current situation where they pay SUM(v4Legacy,V6).
>
> Good Morning Mr. DeLong – 
>
> ARIN can provide registry services for a customer’s IPv6 resources.
> ARIN can provide registry services for a customer’s IPv4 resources.
>
> You can be charged separately for these services – in which case the “Fee cap for IPv4 legacy registry services” that 
> ARIN has instituted gets applied to your IPv4 services invoice. 
> You can be charged combined for these services under a single registration services plan – in which case you gain the 
> benefit of being charged only one amount based the larger of the two resource size categories. 
>
> The “Fee cap for IPv4 legacy registry services” only applies to IPv4 services, and if you have a service plan that 
> includes IPv4 and IPv6 services then the fee cap simply doesn’t apply - you’re just not getting a particular pricing 
> benefit (the IPv4 legacy max fee cap in this case) because you’ve opted to combine everything into a single 
> registration services plan for a difference pricing benefit. 
>
> At no time is a customer being "double-billed” and characterizing it in such a manner is disingenuous.

Customers who choose to retain their LRSA status for their IPv4 resources and have IPv6 resources are being billed more 
for the exact same services (generally approximately double) what customers who have both services under RSA are being 
billed.

It is not disingenuous to call this double billing. This did not used to be the case under the fee structure that 
existed when I signed the LRSA. The ARIN board chose to make this change and as Mr. Herrin has pointed out, when the 
sands shift, there is limited recourse and one cannot simply terminate the contract and return to the pre-contract 
status quo.

As I said, I have solved this problem for my self by transferring the resources that were under LRSA to the RIPE-NCC 
without contract and without fee.

> > Fortunately, the problem is solved for me. I now have my legacy v4 resources registered in RIPE-NCC with no fees and 
> > no contract and my ARIN v6 is, indeed, charged separately, but at least I’m no longer being double-billed.
>
> That’s most excellent - I am glad you’ve found a solution that works for your needs.  I observe that in this case you 
> are being (in your own words) “charged separately” – and that even if a fee applied to your those IPv4 registry 
> services, it would not appropriate to refer to having separate fees for these seperate services such as a 
> circumstance of “double billing”.

I would not be being billed by the same organization. I am, in fact, not being double billed now. RIPE-NCC is not 
billing me at all. I have, for all practical purposes, returned to my pre-LRSA status quo and I encourage other LRSA 
signatories to consider doing the same at this point.

When I signed the LRSA, it was with the express understanding that I wouldn’t be paying additional fees for my IPv4 
resources since MAX(IPv4, IPv6) [ARIN’s traditional billing model and one which persists to this day with the exception 
of the circumstance the board created when they rejiggered the end user fee structure a year or two after I signed the 
LRSA] was equal to IPv6.

Had ARIN persisted in MAX(IPv4, IPv6) for LRSA signatories, we wouldn’t be having this debate. However, ARIN forced 
this particular subset of organizations into SUM(IPv4, IPv6) which is, in effect, double billing them compared to 
RSA-Only organizations.

If ARIN wants to start billing all organizations SUM(IPv4, IPv6), then I will stop calling this double billing because 
it will not be a discriminatory practice and it will be billing those users on the same basis. Alternatively, if ARIN 
starts billing LRSA+RSA organizations on the basis of MAX(IPv4, IPv6), I will also stop calling this double billing.

So long as ARIN persists in this discriminatory billing practice to the disadvantage of LRSA signatories with RSA 
resources, I will continue to call it out as I see it.

Owen