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Charging Scheme Task Force Meeting Minutes (10 February 2025)

10 February 2025

Attendees: Sebastian Brossier, Carlos Friaças, Raymond Jetten, Cynthia Revström, Pavel Odintsov, Piotr Strzyżewski, Clara Wade

Apologies: Alexandru Doszlop, Ivaylo Josifov, Alptekin Sünnetci, Alex de Joode, Ulf Kieber, Victor Bolaños Guerra

Chairs: Ondřej Filip, Peter Hessler

RIPE NCC staff: Fergal Cunningham, Athina Fragkouli, Simon-Jan Haytink, Karla Liddle-White, Marco Schmidt

1. Welcome

RIPE NCC Executive Board Chair, Ondřej Filip, welcomed everyone and confirmed that the agenda had been circulated prior to the meeting. He asked if there were any proposed amendments to the agenda and none were suggested.

2. Presentation from RIPE NCC (Legacy Space)

RIPE NCC Registration Services Manager, Marco Schmidt, presented data on Legacy space, different types of registry update requests, registry workloads and processing times.

He presented the development of contract status of Legacy space holders of IPv4 and ASNs over time. Most legacy space was under contract, he said, but many smaller ranges remain without contracts. Handling legacy requests was labour-intensive and more complex, since they often required tracing historical records. The RIPE NCC is currently processing approximately 100 legacy updates per year. He also noted that Legacy holders without a contract cannot obtain services such as RPKI, so many opt to enter into a contract for these services.

A comparison of registry update requests over time was presented, including M&As, RIPE NCC Service Region transfers, inter-RIR transfers and Legacy updates. His presentation also compared the workload and processing time for these different registry update types, noting the number of annual tickets and average processing time per type.

Marco concluded that the number of requests for different types of Registry updates remained fairly consistent, that all Registry update requests require significant effort from Registration Services, regardless of whether they are for a member or non-member, or fall under Policy Transfer, M&A, Inter-RIR, or Legacy update.

The discussion focused on the high resource demands of Legacy updates, particularly for non-contracted holders. It was noted that eight hours per request equated to a full work day for a single FTE, raising concerns about the sustainability of providing these services without cost recovery from non-members.

There was broad agreement that members should not bear the financial burden for Legacy updates, particularly given that non-contracted holders only engage with the RIPE NCC when they require a service, such as a transfer. A breakdown of legacy updates showed that one-third involved non-contracted holders, while two-thirds were for those under contract. Additionally, non-contracted holders rarely updated their records proactively.

The group agreed that there was a need to review charging structures to ensure fair cost distribution and prevent attempts to circumvent fees while ensuring the accuracy of the Registry.

3. Charging members vs Charging LIRs, and IPv4 allocation fee

RIPE NCC Chief Financial Officer, Simon-Jan Haytink, focused on two potential principles for the draft report: charging on a per-member basis rather than charging per LIR account, and an IPv4 allocation fee if charging would be on a per-member rather than a per-LIR account basis.

Simon-Jan raised the point that if a category-based model was introduced, a decision would need to be made on whether fees should be tied to a RIPE NCC membership or LIRs. He expressed concern that an LIR-based fee structure could encourage the creation of multiple smaller LIRs to fall into lower fee categories and that a charge per membership was preferable. He noted that while members could already create additional memberships, it was operationally burdensome to form separate legal entities to acquire another membership.

The complexity of managing multiple memberships was highlighted, with some participants noting that distinguishing between members and LIRs was often unclear, especially for multinational entities operating across jurisdictions. Operational complexities were also highlighted, with examples of organisations choosing to set up multiple LIRs due to internal structuring preferences, such as managing separate accounts for different branches.

There was general agreement that the charging scheme should not incentivise the creation of additional memberships or legal structures purely for financial benefits or increased voting power at the General Meetings.

Some supported maintaining an LIR-based approach, while others suggested that a member-based model could provide a clearer understanding of the distribution of resources per entity.

Simon-Jan continued to note that members can hold multiple LIR accounts and still retain a single vote, but such a model could incentivise the creation of separate entities to gain additional votes. Some participants suggested that introducing a higher set-up fee for new LIRs could act as a deterrent, though concerns were raised that this could unfairly impact newcomers.

There was then a broader discussion on resource transfers between LIRs held by the same member and whether such movements should be classified as policy transfers.

RIPE NCC Chief Legal Officer, Athina Fragkouli, clarified that resource transfers between LIR accounts held by the same members were also policy transfers, and restrictions such as the 24-month IPv4 holding period still applied.

The issue of charging for IPv4 transfers was also raised, with differing views on whether such transactions should incur fees. Some argued that the financial impact of transfers should be accounted for in the charging scheme, while others believed the discussion should be decoupled from IPv6 and ASN policies.

In conclusion, Simon-Jan stressed the importance of deciding on the underlying principle before drafting a new charging model, as this choice would significantly impact the scheme's structure.

Several participants expressed a preference for member-based charging, arguing that it would create a fairer and more transparent structure. Others stressed the importance of avoiding incentives for system manipulation and ensuring that the model aligns with long-term policy goals. The issue was recognised as significant and that it required further deliberation.

4. Completing Draft CSTF Report Sections

RIPE NCC Head of Membership Engagement, Fergal Cunningham, presented the latest draft of the report. The discussion began with a question of whether the draft report should be published before all sections were complete. It was noted that some areas still required further work.

The group reviewed the readiness of the draft for publication. It was agreed that additional principles for legacy space and resource transfers needed to be developed before proceeding with publication.

While the legacy space topic was deemed outside the scope of the current work and more suitable for discussion within the RIPE community and relevant RIPE working group, it was recognised that principles regarding resource transfers needed further work before the report could be finalised.

A proposed revision to the text suggested that the charging scheme should be based on the principle that organisations pay the majority of their fees to be members of the NCC, rather than for individual services or resources.

There was concern that this principle might be misinterpreted, with some arguing that it could lead to members objecting to paying for certain shared services. It was noted that the membership fee should cover all core services, ensuring a collective financial model rather than a pay-per-service approach.

Some participants pointed out that certain services fluctuate in demand, making it impractical to base revenue on individual usage. It was agreed that discussions about funding specific services should take place during the RIPE NCC Activity Plan process, rather than within the charging scheme discussions. Updates to the wording were made accordingly.

4a. Legacy Address Space

Further discussion focused on the feasibility of updating legacy space without a contract. It was suggested that obtaining information from the RIPE NCC on the complexity of such updates could help determine whether pursuing this was realistic. From a legal perspective, it was noted that legacy transfers without a contract were possible, but VAT implications could complicate implementation. If fees were structured as membership payments, VAT rules would be clear, but if they were applied on a transactional basis, VAT regulations could vary globally, making the approach unfeasible in some cases.

The complexity of handling legacy space updates as a paid-for service across different jurisdictions was raised as another challenge. The level of effort required to manage these legacy updates would depend significantly on local legal and administrative requirements, and maintaining in-house knowledge of each country’s specific regulations was considered impractical. There was concern that significant time could be spent discussing potential fees for non-contracted legacy holders, only to later determine that implementation was unworkable.

The risk of not being able to enforce payment without a contract was also highlighted. It was pointed out that while services could be withheld in the absence of a contract, this could have unintended consequences on the integrity of the registry system, potentially discouraging accurate updates. While legacy-related updates required considerable effort, it was noted that the actual number of such transactions was relatively low, meaning any revenue generated would likely be minimal.

4b. Resource Transfers

Regarding resource transfers, participants considered whether a separate charging scheme for legacy resources could help bridge the gap between contracted and non-contracted resources. There was general agreement that further discussion was needed on how resource transfers should be handled within the charging model before making a final decision.

The discussion then turned to resource transfer statistics, with an interest in reviewing data on how other RIRs were charging for transfers. Simon-Jan clarified that this data was available for task force members to review.

There was also interest in seeing a more detailed breakdown of transfer data, including statistics for IPv4, IPv6, and ASNs. A request was made for data on the size of prefixes being transferred, as well as the total volume of resources moved. It was noted that some of this information was already available, and further data could be provided where necessary.

5. Publication of Draft Report

The group made a commitment to continue refining the principles for legacy space and resource transfers before finalising the report. Future discussions would focus on these areas to ensure well-defined and sustainable charging model principles.

6. AOB

One participant noted that future meetings would be scheduled at a time they would be unable to attend; they expressed hope that everything would proceed smoothly in their absence and they said they would review report updates and minutes as they came through.

Another member raised a question about the publication timeline that needed to be met. It was suggested that this was flexible and dependent on the group’s needs. The upcoming RIPE NCC Executive Board meeting in March was mentioned, though expectations for the report to be delivered then were minimal. It was acknowledged that if a report was not ready in time for the May General Meeting, a progress update could be provided instead.

There was no firm deadline, as speed was not considered a priority over considered, well-thought-through principles and reporting. It was thought that the membership would need to have sufficient time to review and digest the report before any decisions were put to a vote. Additionally, any charging scheme derived from the report should be carefully designed, effectively communicated and properly adopted.

With no further comments, Co-Chair Peter Hessler concluded the meeting and participants were thanked for their time. The next meeting was scheduled to take place in two weeks.