On 7 Apr 2022, at 1:16 PM, Owen DeLong 
<[email protected]<mailto:[email protected]>> wrote:

Moved to ARIN-PPML per your previous advice and your request below...

On Apr 7, 2022, at 09:25 , John Curran 
<[email protected]<mailto:[email protected]>> wrote:
...
However, the “Fee Cap on IPv4 maintenance fees” provided to IPv4 legacy 
resource holders does not apply to such an amount invoiced because the customer 
is being invoiced for a registration services plan that contains multiple items 
[services for IPv4, IPv6, and ASN resources] that are more than just "IPv4 
maintenance fees”.    Customers can keep their IPv4 resources in a separate 
billing relationship and then the “Fee Cap on IPv4 maintenance fees” will 
continue to be applied to their “IPv4 registry maintenance fees”, exactly as 
expected.

It is not a “fee cap” as you express it. It is a rate of increase cap.

Mr. Delong -

You are Incorrect: as noted in the 2018 Fee Consultation - 
<https://www.arin.net/vault/announcements/2018/20180606_feeschedule.html>


  *   Legacy resource holders pay the same annual registry maintenance fees as 
End User organizations ($150 USD for each IPv4 address block and $150 USD for 
each ASN assigned to the organization.) However, there is an annual limit on 
total maintenance fees applicable to legacy resource holder organizations, and 
as of 1 July 2018, the annual limit of total maintenance fees for legacy 
resource holders is set to $125 USD, regardless of the number of legacy 
resources held or version of their Legacy Registration Services Agreement 
(LRSA.)

The "annual limit on total maintenance fees applicable to legacy resource 
holder organizations” is the “fee cap” to which I have been referring, and it 
is only applicable to registry maintenance fees for legacy number resources – 
regardless of the number of legacy resources held.

So, to be clear –


  1.  Organizations can put their IPv4 resources and IPv6 number resources 
under a single registration services plan and be invoiced one amount based on 
the higher of the two categories of resources (IPv4 or IPv6) – but then the 
"annual limit on total maintenance fees for legacy resource holders regardless 
of the number of legacy resources held” does not apply to that amount (since 
there’s more than just IPv4 legacy resources being provided services under that 
plan),  _or_
  2.  Organizations can maintain a separate billing relationship for their IPv4 
legacy resources and then the “annual limit on total maintenance fees for 
legacy resource holders regardless of the number of legacy resources held” (aka 
“fee cap”) continues to be applied to their “IPv4 legacy maintenance fees”, 
exactly as expected.

The choice is entirely the customer’s –  either have one billing relationship 
and gain the benefit of being charged only one amount based the larger of the 
two resource size categories, or maintain separate relations for the IPv4 
legacy resources and gain the benefit of annual total limit on maintenance fees 
for legacy resources.

I don’t have questions in this process at all. I’ve had opinions and we 
disagree. I’ve expressed my opinions and you’ve expressed yours.

I have not been expressing an opinion, but rather explaining how the ARIN fee 
schedule is actually defined and the fact that there is no “double billing” 
involved.  Customers can’t claim the legacy maintenance “fee cap” for 
registration service plans with IPv6 resources in them because the "fee cap" as 
defined is only applicable the registry fees for legacy resources held.

Thanks,
/John

John Curran
President and CEO
American Registry for Internet Numbers

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