North American Network Operators Group

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ULA and RIR cost-recovery

  • From: John Curran
  • Date: Mon Nov 22 14:11:14 2004

I've actually tried to avoid commenting on this thread, but that's obviously
not going work...

Disclaimer:  I am the Chairman of ARIN, but these comments herein are my own
                   musings on this topic and nothing more.

At 2:26 PM -0600 11/19/04, Stephen Sprunk wrote:
>The RIRs' current business models (charging rent for WHOIS and DNS entries) are not compatible with the needs that the IPv6 WG defined, particularly in the cost and paperwork areas.  The odds of success appear to favor a new entity for a new function instead of leeching off an old entity that was designed for a different purpose.

The cost and paperwork associated with current RIR activities is the
consequences of the particular guidelines (think RFC2050) that the
community adopted for IPv4 address space.  This model includes such
parameters as previous assignment history, network deployment plans,
expected utilization rate, Internet connectivity, etc.   As it turns out,
collecting and validating that information takes real people and often
a bit of paperwork.   (In the case of ARIN, the remainder of costs cover
the travel and meetings which are necessary for the open and public
policy formation process, and support for ICANN, emerging registries,
and the RFC editor function.... curious folks can find both the budget
and detailed auditor's reports online at

The IPv4 guidelines are the root cause here, and it's only going to get
more interesting as things get tighter and we begin to look at issues
such as address reclamation...

>>Why set up a separate registry system for
>>these addresses instead of making minor changes to the existing one to
>>accommodate this need?  There is no reason to invent the square wheel
>>manufacturing plant when we have a perfectly good round-wheel plant which
>>can be easily retooled for a fraction of the cost.
>If ARIN, RIPE, APNIC, LACNIC, or AfriNIC wish to provide the service specified in the draft, they're welcome to volunteer for that function. That some folks have considered ULAs a "threat to ARIN's viability" is an indication that it isn't likely.

The particular merits of ULA's aside, there is no reason why the cost to
administer such cannot be very low, but does not appear to be zero due
to the requirements relating to anti-hoarding which will quite likely require
human involvement.  

>Again, in the IPv6 WG there were folks who offerred to operate the ULA registry _for free_,

You'll get what you pay for -- I recently attended a US Senate committee
hearing which dealt with registries and the domain name system.  There
was an enormous amount of questioning about the reliability of these
infrastructure services, and actually not one question about why wasn't
it all free...

The quality (integrity, availability, and survivability) of your assignment
records and inverse DNS services will reflect the investment made.  If
you so much as have a single offsite escrow of the assignments made
to date, you've added an ongoing cost that needs to be recovered.

>and I'm sure many others would be willing to operate it under the initial-cost-only terms in the draft.  The RIRs do not appear to be.

I'm sorry; ARIN operates today under a cost-recovery basis...  What is the basis
of your statement that "The RIRs do not appear to be (willing to operate it under
the initial-cost-only terms in the draft)"?  

If ARIN's members direct it to provide such a service, and provide guidance that
the fees should based initial-only and on a cost recovery, I have a lot of faith that
it would occur...

That does, of course, presume that the operator community actually agrees with
the need for ULA's and draft's philosophy on pricing.