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Re: NIR SIG Proposal at APNIC-18 - Changing NIR fee structure
Toshi,
Thanks for this submission. Hope we can have a good
disucussion and result on this proposal.
Regards,
Akinori, Chair of NIR-SIG
In message <20040804145732.75AA.HOSAKA@nic.ad.jp>
"NIR SIG Proposal at APNIC-18 - Changing NIR fee structure"
"Toshiyuki Hosaka <hosaka@nic.ad.jp>" wrote:
| Dear Maemura-san and all NIR colleagues,
|
| The following is another proposal from JPNIC, which I have submitted by
| email today. Your questions, comments, and suggenstions are highly
| appreciated.
|
| Looking forward to seeing you all in Fiji.
|
| Thanks and best regards,
| Toshi@JPNIC
|
| ----------------
|
| Proposal: Changing NIR fee structure
| Author: Toshiyuki Hosaka, Japan Network Information Center (JPNIC)
| Version 1.0 as of August 4, 2004
|
| _____________________________________________________________________
| Introduction:
| (A very brief description of your proposal.)
| ---------------------------------------------------------------------
|
| This document proposes new NIR fee structure, which could be acceptable
| for all stakeholders, i.e., APNIC, APNIC members, and NIRs. This
| proposed fee structure sets an per allocation fee charged to NIRs
| (indirectly to NIR members) at a reasonable level even when NIRs make
| a large allocation to their members, by setting an upper limit to the
| fee.
|
|
| _____________________________________________________________________
| Summary of the current problem:
| (Describe the situation that this proposal is intended to address.)
| ---------------------------------------------------------------------
|
| NIRs are charged NIR fees, or per address fee, defined in APNIC-103
| (Operational policies for National Internet Registries in the APNIC
| region), in addition to yearly membership fee, which all APNIC members
| pay as well.
|
| 1.3 NIR fees
| ----------------
|
| APNIC charges fees for providing NIR services. These fees are set at
| a level that ensures that other APNIC members do not subsidise NIR
| members and that NIRs provide sufficient funding to cover the cost of
| providing the services they require. Details of the NIR fees are
| described in the APNIC document "APNIC Fee Schedule: Membership
| Tiers, Fees, and Descriptions", within the provisions describing the
| 'per address fee' for confederations.
|
|
| This NIR fees increase in proportion to the address space allocated to
| NIRs (or NIR members), and there is no upper limit in the fee. This is
| the problem for NIRs/NIR members especially in large allocation.
|
| For exapmle;
|
| /10 in IPv4 : 4,194,304 * USD 0.02 (Extra Large) = USD 83,886.08
| /20 in IPv6 : 5,534,417 * USD 0.02 (ditto) = USD 110,688.34
|
| Such large allocations are feasible for JPNIC members. Our IPv4 address
| allocation size to our members shows a trend of increase. JPNIC has made
| 5 allocations exceeding /14 in recent 12 months, from July 2003 to June
| 2004, for instance.
|
| Furthermore, revised IPv6 policy document (prop-016-v002) clarifies
| that LIRs can apply for larger IPv6 allocations based on the current
| IPv4 infrastructure, and that the allocation size is decided in
| accordance with the HD-ratio. So it is very likely for our members to
| request larger IPv6 allocations. In fact, JPNIC had inquiries recently
| from two of our members regarding large IPv6 allocation at /20 level.
|
| This is actually a huge amount of fee, larger than yearly APNIC/JPNIC
| membership fee. JPNIC has to pass such cost to our members in either
| ways as below;
|
| a) JPNIC passes this cost on our members
| b) JPNIC passee this cost on the requestor
|
| Choice a) is not acceptable for JPNIC because this means small/medium
| ISPs are to pay larger ISP's per allocation fee.
|
| Choice b) also has problems as below;
|
| 1) NIR members may lose the motivation to request large allocations
| under NIR membership, since the expense is far larger than receiving
| allocations directly from APNIC. This is not the situation we want.
|
| 2) This large per address fee is beyond the level that NIRs can
| justify as "value added service", such as local language/whois/
| information/translation.
|
| 3) This large per address fee is beyond the intention described in
| APNIC-103.
|
| 4) In order to avoid a per allocation fee, NIR members *may* receive
| the large amount of IP resources as an APNIC member and after that
| it *may* transfer its membership to NIR. This causes much burden
| both APNIC and NIRs.
|
| 5) If Large NIR members flow out to APNIC direct membership, APNIC's
| opration cost could increase which might be transfered to membership
| fee applied to all APNIC members in the long run.
|
| _____________________________________________________________________
| Situation in other RIRs:
| (If applicable, describe any policies which may apply to this
| situation in ARIN,LACNIC, or RIPE NCC. If you are not sure, leave
| this section blank.)
| ---------------------------------------------------------------------
|
| (blank)
|
|
| _____________________________________________________________________
| Details of your proposal:
| (Describe your proposal in detail.)
| ---------------------------------------------------------------------
|
| JPNIC proposes to "set an upper limit on the per address fee for NIRs".
| Non-NIR confederations is not the target of this proposal.
|
| This proposal consists of two parts. Details are as follows;
|
|
| (1) JPNIC proposes to set an upper limit on the per address fee
| for a single allocation, provided that the NIRs make an
| allocation from APNIC common address pool (including Direct
| Member Allocation).
|
| (2) JPNIC tentatively proposes that the upper limit of per address
| fee for a single allocation should be set at /14 in IPv4, and
| /28 in IPv6. However, this specific value is subject to a
| financial impact assessment by APNIC.
|
|
| Proposed per address fee is calculated as follows;
|
| (IPv4)
| /20 : 4,096 * (per address fee)
| /19 : 8,192 * (per address fee)
| /18 : 16,384 * (per address fee)
| /17 : 32,768 * (per address fee)
| /16 : 65,536 * (per address fee)
| /15 : 131,072 * (per address fee)
| /14 : 262,144 * (per address fee)
| /13 : 262,144 * (per address fee)
| /12 : 262,144 * (per address fee)
| ... ...
|
|
| (IPv6)
| /32 : 7,132 * (per address fee)
| /31 : 12,417 * (per address fee)
| /30 : 21,619 * (per address fee)
| /29 : 37,641 * (per address fee)
| /28 : 65,536 * (per address fee)
| /27 : 65,536 * (per address fee)
| /26 : 65,536 * ...
| ... ...
|
|
| _____________________________________________________________________
| Advantages and disadvantages of adopting the proposed policy:
| (Explain what you believe to the be the main advantages and
| disadvantages that would flow if APNIC adopted your proposal.)
| ---------------------------------------------------------------------
|
| 1. Why adopt the upper limit for per address fee?
|
| Changing the fee structure should be acceptable for all the stakeholders,
| APNIC, APNIC members, and NIRs (NIR members). That is;
|
| (1) For APNIC
| - New structure should not have siginificant inpact on APNIC financlal
| condition.
|
| (2) For APNIC members
| - New structure should not force current APNIC members to pay additional
| fee.
|
| (3) For NIRs (NIR members)
| - New structure should solve current problem.
| - New structure should not cause unfairness amoung NIRs.
|
| When we see those points, this proposal meets points mentioned above.
|
|
| 2. Other choices?
|
| 2.1 Discount per address (site) fee
|
| Even if you discount per address fee (ex. USD 0.02 to USD 0.01), it
| won't help NIR so much since there is still no upper limit for per
| address fee.
|
|
| 2.2 Implement allocation fee (fixed fee per allocation)
|
| If this scheme is implemented, APNIC has to charge larger fee than
| current per address fee corresponds to /20 or /19, in order to keep
| the revenue from NIRs. This means smaller NIRs and NIR members are
| charged more than current scheme, and this is not aceptable for them.
|
|
| 2.3 Raise membership fee for NIRs
|
| This could be an appropriate solution for the problems, however we
| do not take this here since we cannot propose concrete NIR fee
| structure which is acceptable for all NIRs without knowing how much
| each NIR pays yearly including both membership fee and NIR fees.
|
|
| 2.4 Revise current fee structure as a whole, involving all APNIC
| members
|
| It takes time and probably this is not acceptable for current APNIC
| members.
|
|
| 3. Why 262,144 hosts (65,536 sites in IPv4) are the upper limit?
|
| Based on the stats JPNIC has, /14 (in IPv4) is the appropriate level
| we can agree on. If we set the upper limit at /14, APNIC doesn't lose
| much revenue from NIRs since currently there are not so many allocation
| over /14.
|
| Below is the JPNIC allocation made to the members.
|
| (1) Recent 12 months (July 2003 to June 2004)
|
| /14+ : 5 (3%)
| /14 and under : 185 (97%)
| ----------
| /11+ : 0
| /12 : 2
| /13 : 3
| /14 : 1
| /15 : 6
| /16 : 15
| /17 : 11
| /18 : 20
| /19 : 37
| /20 : 95
| -----------
|
| (2) January 2002 to December 2002
|
| /14+ : 2 (0.8%)
| /14 and under : 236 (99%)
|
| (3) January 2001 to December 2001
|
| no /14+ allocation
|
|
| 4. Why restrict to the allocation made from APNIC common address pool?
|
| Without this restriction, NIRs with its own pool can pay less than NIRs
| allocating from APNIC pool, which may cause serious impact on APNIC
| revenue. For example;
|
| (Case-1)
| - When APNIC allocates /12 (4*/14) to NIRs as their address pool,
| and NIRs allocate 4 * /14 to their members...
|
| 262,144 * USD 0.02 = USD 5,242.88 (/14 limit applied)
|
| +-------+ +------+ +-----+
| | APNIC |-----| NIRs |-------| LIR |
| +-------+ +------+ | +-----+
| ----> | +-----+
| /12 |---| LIR |
| | +-----+
| |---
| ..
| ..
| ------>
| 4 * /14
|
| In this case NIRs are to pay only USD 5,242.88, and can allocate
| 4 * /14 to their members.
|
| (Case-2)
| - When NIRs allocate 4*/14 to their members from APNIC addres pool...
|
| 262,144 * 4 * USD 0.02 = USD 20,971.52 >> USD 5,242.88
|
| +-------+ +------+
| | APNIC |-----| NIRs |------+
| +-------+ +------+ |
| | +--+--+
| |------------------->| LIR |
| | /16 +-----+
| | +-----+
| |------------------->| LIR |
| | /16 +-----+
| .. ..
| .. ..
|
| In this case NIRs are to pay USD 20,971.52, much larger than case-1.
| So we should have the restriction that proposed upper limit is only
| applicable to the allocation made from APNIC common address pool.
|
|
| (*remark) ----------------------------------------------------------
| Per address fee here is the one applied to ex.large members, and set
| /14 upper limit.
| --------------------------------------------------------------------
|
|
| In IPv6 case all NIRs allocate IPv6 block from APNIC pool so this
| restriction is not applied. /28 (in IPv6) limit for per address fee
| is applied to all NIRs.
|
|
| 5. Detailed financial impact on APNIC operation
|
| (Subject to the calculation by APNIC)
|
|
| _____________________________________________________________________
| Effect on APNIC members:
|
| Briefly explain how you think this may affect APNIC members. For
| example will APNIC members save costs, have more efficient
| administrative procedures, and so on.
| ---------------------------------------------------------------------
|
| There is no negative impact on current APNIC members.
|
|
| _____________________________________________________________________
| Effect on NIRs:
|
| Briefly explain how you think this may affect NIRs. If you are not
| sure, leave this section blank.
| ---------------------------------------------------------------------
|
| There is no fee raise for NIRs, and large NIR members can stay NIR
| membership so all NIR and NIR members have a merit.
|
| (end of document)
|
|
|
|
| --
| Toshiyuki Hosaka <hosaka@nic.ad.jp>
| Japan Network Information Center (JPNIC)
| Tel: +81-(0)3-5297-2311 Fax: +81-(0)3-5297-2312
|
|
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| sig-nir@lists.apnic.net
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