I concur. I’m also + 1 Dave Farmers comments.

Thanks!



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________________________________
From: ARIN-PPML <arin-ppml-boun...@arin.net> on behalf of Michael B. Williams 
via ARIN-PPML <arin-ppml@arin.net>
Sent: Saturday, June 3, 2023 1:23:52 PM
To: Tom Fantacone <t...@iptrading.com>
Cc: arin-ppml <arin-ppml@arin.net>
Subject: Re: [arin-ppml] Tenfold fee increases?

I believe the conversation is valid and should continue… if there is another 
active list that is a better fit then move it there but as Tom pointed out this 
seems to be the most appropriate list.

My vote is to keep the conversation going.

Michael

On Sun, Jun 4, 2023 at 01:59 Tom Fantacone 
<t...@iptrading.com<mailto:t...@iptrading.com>> wrote:
Heather,

I wish I could have posted this on arin-discuss@, but it's been shut down as 
you know.

While ARIN's fee structure is not set by policy, extravagant fee increases do 
have a very practical effect on the implementation of policy, and I think it's 
appropriate to discuss here, as prior excessive fee increases have been 
discussed in the past.  For instance, were ARIN to increase resource transfer 
fees from $500 to $50,000, it would certainly impact Section 8 transfers.  Were 
ARIN to increase IPv6 annual resource fees by a factor of 10, that would impact 
IPv6 deployment and could induce members suggest policy changes to compensate.

I'm not questioning the board's right to set fees.  I'm questioning their 
judgment.  The board may have good reasons for large fee increases, but I'm 
skeptical and suggest when contemplating very large increases, or changes to 
fee structures that greatly impact certain organizations (like billing end 
users Orgs as ISPs), there be some transparency and requests for community 
comments BEFORE it's a done deal.

The moderators can shut this down if they choose.  I'd prefer to hear some 
feedback from those who made the decisions on these fee hikes.

Regards,

Tom Fantacone



---- On Sat, 03 Jun 2023 10:19:59 -0400 Heather Schiller 
<heather.ska...@gmail.com<mailto:heather.ska...@gmail.com>> wrote ---

ARIN moderators -- please consider moving or closing this thread.

Folks, ARIN fees are not set through the Policy Development Process.  The board 
sets fees and has the fiduciary responsibility to ARIN.  Direct complaints to 
the Board, maybe the suggestion process, ARIN feedback surveys or the open 
discussion at membership portion of meetings.

arin-discuss@ would have been the appropriate forum.  Perhaps general-members@ 
is a better fit.

 --h

On Fri, Jun 2, 2023 at 5:03 PM Mike Burns 
<m...@iptrading.com<mailto:m...@iptrading.com>> wrote:



“All that said, I couldn’t find any justification for the increase from $1,000 
to $10,000. If there is justification or other details regarding the increase, 
I’d appreciate a pointer to them.”





Hi David,



Reading the new contract it’s clear that ARIN’s intention here is to avoid any 
liability through imputed approval of listed brokers.

So there is a twofold  approach. First, have all the brokers more explicitly 
abjure any legal connection with ARIN and second, reduced the likelihood of a 
problem by filtering out risky brokers.



I wonder if the board became spooked by something.  Seems like even bolder 
disclaimers on the broker page could have handled the liability risk, but IANAL.



It brings to mind this suggestion: 
https://www.arin.net/vault/participate/acsp/suggestions/2018-20-suggestion.pdf



Speaking as a broker who can easily qualify, this will certainly benefit us as 
it will limit our competitor’s access.

And not just small brokers, but overseas brokers! Thanks ARIN, we can be listed 
brokers at the other trading RIRs, and also at ARIN!

So you can’t be a sole proprietor because you need two responsible contacts. 
And you have to be organized as a business.

There are a few brokers I know who are good brokers, but not really full-time 
brokers, who are on the list.

Anyway, the insurance requirement, the background checks, the $10K annual fee, 
all these make sense if you understand the intention of reducing ARIN risk 
exposure.

The loss of small and overseas brokers, the reduced competition, well those are 
collateral damages that the board seems to have accepted.



I do agree with David that $100 was too low and with Tom (and many other 
brokers) that $10,000 is too high. And that there should be some venue for 
discussion of fees.



I wonder why ARIN alone feels this pressure, the other RIR broker lists don’t 
seem to.



Regards,
Mike



PS I am not buying the argument that ARIN feels compelled to do this to protect 
innocent members from bad brokers, but I will admit that could be a motivation

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