I oppose the policy *as worded* for the reason(s) expressed below. On 2020-03-24 10:20, ARIN wrote: > On 19 March 2020, the ARIN Advisory Council (AC) accepted > "ARIN-prop-285: IPv6 Nano-allocations" as a Draft Policy.
[snip] > Draft Policy ARIN-2020-3: IPv6 Nano-allocations > > Problem Statement: > > ARIN's fee structure provides a graduated system wherein organizations > pay based on the amount of number resources they consume. The wording of this problem statement is, IMO, incorrect. ARIN's RSA, Section 7, explicitly states that number resources are not the property of the holder. As such, I don't see how a reasonable person can view them as being "consumed" by the registrant. This may seem like a semantic issue, but part of the problem is that the statement is really correct inasmuch as the ARIN fee schedule does scale based on the amount of IP addresses registered to an organization, rather than based on the registration services actually provided by ARIN. The elephant in the room is that ARIN's fee schedule treats IP addresses as some sort of scarce property rather than properly recovering the costs of the services ARIN provides. And yes, I understand how hard this is: I was on an ARIN fee schedule committee about 5-6 years ago. That experience taught me that creating a fee schedule that properly accounts for the costs that accrue to ARIN for the services it provides to the community is really hard. But it also gave me an inkling that there might be a better way than treating IP addresses as consumable property and charging for their scarcity. The alignment between that and ARIN's operating costs is just too tenuous. The policy is represents good intent, and from a technical perspective, I don't have a problem with it. /40s-/48s appear in the IPv6 DFZ as a result of direct assignments obtained by end sites via the "PIv6" policies ratified by ARIN and other RIRs over a decade ago (which I supported). I agree that ship has sailed. I also acknowledge, as I did during the PIv6 debates and despite my support for PIv6, that the costs of micro-allocations are actually borne by the operator community who must provision additional FIB capacity to support bigger routing tables. I would state that routing capacity has arguably scaled better than we thought back in the mid-00s, and we have dealt with that, as is our job as operators. But it underscores that ARIN's fee schedule doesn't account for such externalities. One could argue that it shouldn't, but if that's the case, why does it try to account for the externality of scarcity of number resources? Why doesn't it just account for ARIN's costs? And more broadly, how many more band-aids are we willing to put on the current fee structure? If the answer is "oh, we can handle at least a few more band-aids," then fine. Change the word "consume" to something else, and prepend the problem statement with "For better or worse," and we're done. But I feel like we should at least think about the larger question. michael _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues.
