On 17 Sep 2021, at 3:52 AM, 
[email protected]<mailto:[email protected]> wrote:

Some have suggested the fee should not have a relationship to the number of 
addresses, but I strongly disagree.

For the most part, the more addresses you have, the more SWIP transactions and 
reverse lookups and customer service transactions are going to take place, so 
it is quite proportional.

Albert –

This is incorrect – i.e. the assertion that ARIN’s costs are proportional to 
the span of address space represented by registry objects – and it is also 
likely beyond the possibility of physics (as noted below.)

Larger entities almost always have dedicated personal who knowledgable of ARIN 
and our processes – while they may make some additional customer services 
transactions (due to acquiring additional resources or using more advanced 
services), it would be highly unusual for any of them to make hundreds of more 
frequent customer service requests, let alone the thousands, or hundreds of 
thousands, that you suggest and would be necessary for ARIN to bear a 
proportional cost burden due to servicing such organizations.

There are significant fixed costs of operating the registry and these fixed 
costs are predominately related to the number of organizations that must have 
billing relationships with ARIN and the number of resource entries in the 
registry – they are _not_ proportional in any manner to the size of the address 
space span represented by the registry objects.

Note – In 2014, the previously mentioned Fee Structure Review Panel looked at 
an approach that sought recover a fixed amount per registry object and use 
rather significant transactions fees to correspond more directly to the level 
of effort for recovering costs of registration service requests (aka Proposal 
#7 “Transaction Fee Proposal” in the previously referenced report.)  It was 
clear that such an approach would quite significantly penalize the smaller 
registry users, as it results in per registry object fees of more than $800 per 
object per year and larger  transaction fees. The fact of the matter is that 
ARIN’s present geometric registry fee scale burdens organizations with the 
largest number resource holdings far in excess of their imputed costs to ARIN, 
and while this is obvious, it was also felt to be overall reasonable because 
the _benefit_ obtained could also be deemed to be disproportionate.

FYI,
/John

John Curran
President and CEO
American Registry for Internet Numbers




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