From info at arin.net Tue Aug 3 08:13:53 2021 From: info at arin.net (ARIN) Date: Tue, 03 Aug 2021 08:13:53 -0400 Subject: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement Message-ID: <0E93A587-E9FC-47F6-8554-2B0C681BE92F@arin.net> ARIN regularly reviews existing processes as part of our continual improvement efforts to be more responsive and improve the service our customers receive from ARIN. Recently ARIN reviewed the Officer Attestation process and as a result of that review have determined the Officer Attestation process is no longer necessary for achievement of its original goals and should be retired. The purpose of this consultation is to review this proposed change with the community prior to its implementation. The Officer Attestation was introduced in 2007 in preparation for the depletion of IPv4 addresses. Currently, ARIN requires an Officer Attestation for all requests that involve a needs analysis (which today consist of waiting list requests, NRPM 4.4 micro-allocations, NRPM 4.10 IPv6 transition, IPv6 requests, and transfer recipient requests.) However, conditions have changed since this requirement was established, and ARIN believes that the Officer Attestation for resource request tickets is no longer necessary for the following reasons: - Today IPv4 resources are issued by ARIN predominantly via the Waitlist policy, and this policy has been revised to only allow one small request per party (thus avoiding the original risk of ?hoarding? via large suspect requests prior to runout). - With regard to transfers of IPv4 resources obtained via the transfer market, the inherent costs for large transfers ensures organizational officers are ?in the know?. - Given IPv6 availability, officer attestation of need for IPv6 resources is not necessary. The review identified that at this point in time the Officer Attestation process is problematic for many customers, predominantly posing an administrative burden that does not materially improve policy implementation and resulting in numerous complaints and adding unnecessary delay (varying between two days and an entire week) to completion of resource request tickets. In light of the administrative burden to customers and undefined benefit, ARIN proposes dropping the Officer Attestation requirement ? note that this specifically does not change documentation requirements related organization recovery of IP number resources or related anti-fraud measures that ARIN has implemented. This consultation will remain open for 10 days. Please provide comments to arin-consult at arin.net. You can subscribe to this mailing list at: http://lists.arin.net/mailman/listinfo/arin-consult. Discussion on arin-consult at arin.net will close on 13 August 2021. Regards, John Curran President and CEO American Registry for Internet Numbers (ARIN) From Marla.Azinger at FTR.com Tue Aug 3 08:53:37 2021 From: Marla.Azinger at FTR.com (Azinger, Marla) Date: Tue, 3 Aug 2021 12:53:37 +0000 Subject: [ARIN-consult] Attestation removal Message-ID: I didn't think it did anything other than slow up a process anyway. Out of curiosity. Did you see requests die or change when it got to the attestation part? Marla Azinger Frontier Communications IP Management - IP Network Activation ________________________________ This communication is confidential. Frontier only sends and receives email on the basis of the terms set out at http://www.frontier.com/email_disclaimer. -------------- next part -------------- An HTML attachment was scrubbed... URL: From jcurran at arin.net Tue Aug 3 09:11:56 2021 From: jcurran at arin.net (John Curran) Date: Tue, 3 Aug 2021 13:11:56 +0000 Subject: [ARIN-consult] Attestation removal In-Reply-To: References: Message-ID: <3E9E7B28-02BE-4711-8CF5-D1B63EFE9D0E@arin.net> On 3 Aug 2021, at 8:53 AM, Azinger, Marla > wrote: I didn't think it did anything other than slow up a process anyway. Out of curiosity. Did you see requests die or change when it got to the attestation part? Marla - The predominant issue has been delays of tickets ? while we don?t separately track abandonment or modification during the officer attestation phase, but as the overwhelming majority of tickets are successfully completed it stands to reason that such events are very rare indeed. Thanks! /John John Curran President and CEO American Registry for Internet Numbers -------------- next part -------------- An HTML attachment was scrubbed... URL: From jcurran at arin.net Tue Aug 3 09:15:47 2021 From: jcurran at arin.net (John Curran) Date: Tue, 3 Aug 2021 13:15:47 +0000 Subject: [ARIN-consult] Attestation removal (resend) In-Reply-To: References: Message-ID: On 3 Aug 2021, at 8:53 AM, Azinger, Marla > wrote: I didn't think it did anything other than slow up a process anyway. Out of curiosity. Did you see requests die or change when it got to the attestation part? Marla - The predominant issue has been delays of tickets. While we don?t separately track abandonment or modification during the officer attestation phase, the overwhelming majority of tickets are successfully completed ? so it stands to reason that such events (if they occur at all) are rather rare indeed. Thanks! /John John Curran President and CEO American Registry for Internet Numbers -------------- next part -------------- An HTML attachment was scrubbed... URL: From rs at seastrom.com Tue Aug 3 09:47:14 2021 From: rs at seastrom.com (Rob Seastrom) Date: Tue, 3 Aug 2021 09:47:14 -0400 Subject: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement In-Reply-To: <0E93A587-E9FC-47F6-8554-2B0C681BE92F@arin.net> References: <0E93A587-E9FC-47F6-8554-2B0C681BE92F@arin.net> Message-ID: > On Aug 3, 2021, at 8:13 AM, ARIN wrote: > > ... conditions have changed since this requirement was established, and ARIN believes that the Officer Attestation for resource request tickets is no longer necessary for the following reasons: > > - Today IPv4 resources are issued by ARIN predominantly via the Waitlist policy, and this policy has been revised to only allow one small request per party (thus avoiding the original risk of ?hoarding? via large suspect requests prior to runout). To what degree did the requirement for officer attestation contribute to ARIN staff smoking out the abuse of the waitlist that resulted in the revision of the policy a couple of years back? Is there any kind of downside in terms of getting law enforcement involved for fraudulent requests if we get rid of this requirement? That is to say, does LE view the application differently with vs. without the officer attestation when evaluating whether there was an act that they're going to use scarce prosecutorial resources on? Interested in Counsel's take on this. > - With regard to transfers of IPv4 resources obtained via the transfer market, the inherent costs for large transfers ensures organizational officers are ?in the know?. That depends on the size of the organization. The cost of a /16 on the transfer market is a rounding error in some departmental budgets, with no particular visibility to people at a level that we think of as corporate officers. > - Given IPv6 availability, officer attestation of need for IPv6 resources is not necessary. I have never been wholly in favor of requiring an officer attestation for resources for which there is no scarcity/hoarding incentive (i.e. IPv6 blocks and 32 bit ASNs). For those resources I agree that the administrative burden significantly exceeds any potential upside. For IPv4 number resources, my position requires some more thought and am eagerly anticipating more community input. > The review identified that at this point in time the Officer Attestation process is problematic for many customers, predominantly posing an administrative burden that does not materially improve policy implementation and resulting in numerous complaints and adding unnecessary delay (varying between two days and an entire week) to completion of resource request tickets. > > In light of the administrative burden to customers and undefined benefit, ARIN proposes dropping the Officer Attestation requirement ? note that this specifically does not change documentation requirements related organization recovery of IP number resources or related anti-fraud measures that ARIN has implemented. This is an interesting analysis and I look forward to seeing it, along with the results of this consultation, in a future Policy Experience Report. Thank you! -r From jcurran at arin.net Tue Aug 3 10:15:27 2021 From: jcurran at arin.net (John Curran) Date: Tue, 3 Aug 2021 14:15:27 +0000 Subject: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement In-Reply-To: References: <0E93A587-E9FC-47F6-8554-2B0C681BE92F@arin.net> Message-ID: <98342EF6-685B-4341-8788-20F30922C842@arin.net> On 3 Aug 2021, at 9:47 AM, Rob Seastrom wrote: >> On Aug 3, 2021, at 8:13 AM, ARIN wrote: >> ... conditions have changed since this requirement was established, and ARIN believes that the Officer Attestation for resource request tickets is no longer necessary for the following reasons: >> >> - Today IPv4 resources are issued by ARIN predominantly via the Waitlist policy, and this policy has been revised to only allow one small request per party (thus avoiding the original risk of ?hoarding? via large suspect requests prior to runout). > > To what degree did the requirement for officer attestation contribute to ARIN staff smoking out the abuse of the waitlist that resulted in the revision of the policy a couple of years back? Officer attestation did not contribute to the detection - by definition, the parties who utilized the waitlist were requests whose need assessment supporting documentation was attested to and then approved. (One can theorize that even large requests would have been made absent such attestations but that would be purely conjecture.) > Is there any kind of downside in terms of getting law enforcement involved for fraudulent requests if we get rid of this requirement? That is to say, does LE view the application differently with vs. without the officer attestation when evaluating whether there was an act that they're going to use scarce prosecutorial resources on? Interested in Counsel's take on this. The proposed change has been reviewed with ARIN?s legal counsel prior to recommendation to the community. As a person intimately familiar with the prosecution of fraudulent requests here at ARIN, I can say that the change to drop attestation of needs-request documentation should not materially affect our anti-fraud processing. > ... > I have never been wholly in favor of requiring an officer attestation for resources for which there is no scarcity/hoarding incentive (i.e. IPv6 blocks and 32 bit ASNs). For those resources I agree that the administrative burden significantly exceeds any potential upside. It is true that the change regarding attestation for IPv4 blocks is enabled as a result of being post-depletion with ARIN issuance per the waitlist being of very modestly-sized IPv4 blocks. Under such circumstances the officer attestation is a lengthy delay to certify information which is rather routine in both information and scope. > For IPv4 number resources, my position requires some more thought and am eagerly anticipating more community input. Acknowledged (and thanks!) /John John Curran President and CEO American Registry for Internet Numbers From farmer at umn.edu Tue Aug 3 10:28:33 2021 From: farmer at umn.edu (David Farmer) Date: Tue, 3 Aug 2021 09:28:33 -0500 Subject: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement In-Reply-To: <0E93A587-E9FC-47F6-8554-2B0C681BE92F@arin.net> References: <0E93A587-E9FC-47F6-8554-2B0C681BE92F@arin.net> Message-ID: Officer Attestation has been written into ARIN policy in two places; Section 8.5.5. [Specified Transfer] Block Size, and the last paragraph of Section 9. Out of Region Use. I assume the changes to ARIN's processes and procedures proposed by this consultation WOULD NOT affect these two situations, unless or until an actual policy change is implemented through the PDP. Is this a correct assumption? Therefore, this consultation only relates to other situations where an Officer Attestation is included in ARIN's processes and procedures and not those that are written into ARIN policy. Based on that assumption, I support the changes proposed in this consultation. Furthermore, I do not support any changes to policy regarding Officer Attestation at this time. Thank You. -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== -------------- next part -------------- An HTML attachment was scrubbed... URL: From scottleibrand at gmail.com Tue Aug 3 12:21:14 2021 From: scottleibrand at gmail.com (Scott Leibrand) Date: Tue, 3 Aug 2021 09:21:14 -0700 Subject: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement In-Reply-To: <98342EF6-685B-4341-8788-20F30922C842@arin.net> References: <98342EF6-685B-4341-8788-20F30922C842@arin.net> Message-ID: <6A3AF36B-E071-4C64-91E8-D5FBB1936E6E@gmail.com> I support removal of the attestation requirement. It has now outlived its original purpose, and likely wouldn?t pass a cost-benefit test if proposed today. Scott > On Aug 3, 2021, at 7:15 AM, John Curran wrote: > > ?On 3 Aug 2021, at 9:47 AM, Rob Seastrom wrote: >>>> On Aug 3, 2021, at 8:13 AM, ARIN wrote: >>> ... conditions have changed since this requirement was established, and ARIN believes that the Officer Attestation for resource request tickets is no longer necessary for the following reasons: >>> >>> - Today IPv4 resources are issued by ARIN predominantly via the Waitlist policy, and this policy has been revised to only allow one small request per party (thus avoiding the original risk of ?hoarding? via large suspect requests prior to runout). >> >> To what degree did the requirement for officer attestation contribute to ARIN staff smoking out the abuse of the waitlist that resulted in the revision of the policy a couple of years back? > > Officer attestation did not contribute to the detection - by definition, the parties who utilized the waitlist were requests whose need assessment supporting documentation was attested to and then approved. (One can theorize that even large requests would have been made absent such attestations but that would be purely conjecture.) > >> Is there any kind of downside in terms of getting law enforcement involved for fraudulent requests if we get rid of this requirement? That is to say, does LE view the application differently with vs. without the officer attestation when evaluating whether there was an act that they're going to use scarce prosecutorial resources on? Interested in Counsel's take on this. > > The proposed change has been reviewed with ARIN?s legal counsel prior to recommendation to the community. As a person intimately familiar with the prosecution of fraudulent requests here at ARIN, I can say that the change to drop attestation of needs-request documentation should not materially affect our anti-fraud processing. > >> ... >> I have never been wholly in favor of requiring an officer attestation for resources for which there is no scarcity/hoarding incentive (i.e. IPv6 blocks and 32 bit ASNs). For those resources I agree that the administrative burden significantly exceeds any potential upside. > > It is true that the change regarding attestation for IPv4 blocks is enabled as a result of being post-depletion with ARIN issuance per the waitlist being of very modestly-sized IPv4 blocks. Under such circumstances the officer attestation is a lengthy delay to certify information which is rather routine in both information and scope. > >> For IPv4 number resources, my position requires some more thought and am eagerly anticipating more community input. > > Acknowledged (and thanks!) > /John > > John Curran > President and CEO > American Registry for Internet Numbers > > > > _______________________________________________ > ARIN-Consult > You are receiving this message because you are subscribed to the ARIN Consult Mailing > List (ARIN-consult at arin.net). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN Member Services > Help Desk at info at arin.net if you experience any issues. From jcurran at arin.net Tue Aug 3 12:21:31 2021 From: jcurran at arin.net (John Curran) Date: Tue, 3 Aug 2021 16:21:31 +0000 Subject: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement In-Reply-To: References: <0E93A587-E9FC-47F6-8554-2B0C681BE92F@arin.net> Message-ID: <30F16B11-0912-4F58-9DEA-7C221AF28EC6@arin.net> On 3 Aug 2021, at 10:28 AM, David Farmer via ARIN-consult > wrote: From: David Farmer > Subject: Re: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement Date: 3 August 2021 at 10:28:33 AM EDT To: ARIN > Cc: ">" > Officer Attestation has been written into ARIN policy in two places; Section 8.5.5. [Specified Transfer] Block Size, and the last paragraph of Section 9. Out of Region Use. That is correct. There?s also additional operational processes that call officer attestation related to parties recovering rights to number resources which are no longer appropriately attributed in the registry, and related anti-fraud situations. I assume the changes to ARIN's processes and procedures proposed by this consultation WOULD NOT affect these two situations, unless or until an actual policy change is implemented through the PDP. Is this a correct assumption? That is correct - the proposed change to officer attestation is only for needs-assessment document requests and would not affect the two circumstances specified in the NRPM. Therefore, this consultation only relates to other situations where an Officer Attestation is included in ARIN's processes and procedures and not those that are written into ARIN policy. Based on that assumption, I support the changes proposed in this consultation. Excellent - good to know. Furthermore, I do not support any changes to policy regarding Officer Attestation at this time. Acknowledged, and for avoidance of doubt, ARIN staff is not suggesting any changes to number resource policy in this regard either. Thanks! /John John Curran President and CEO American Registry for Internet Numbers -------------- next part -------------- An HTML attachment was scrubbed... URL: From rs at seastrom.com Tue Aug 3 13:42:02 2021 From: rs at seastrom.com (Rob Seastrom) Date: Tue, 3 Aug 2021 13:42:02 -0400 Subject: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement In-Reply-To: <30F16B11-0912-4F58-9DEA-7C221AF28EC6@arin.net> References: <0E93A587-E9FC-47F6-8554-2B0C681BE92F@arin.net> <30F16B11-0912-4F58-9DEA-7C221AF28EC6@arin.net> Message-ID: <2B0B8A50-1BB0-4841-B65E-7BC7E2E58A12@seastrom.com> > On Aug 3, 2021, at 12:21 PM, John Curran wrote: > >> >> Furthermore, I do not support any changes to policy regarding Officer Attestation at this time. > > Acknowledged, and for avoidance of doubt, ARIN staff is not suggesting any changes to number resource policy in this regard either. > Thank you for that clarification since that is exactly what I thought was being suggested. That's why I said that I looked forward to seeing these observations as well as the outcome of this consultation in a future policy experience report. It seems to me that if there is sufficient support through a consultation process for removal of officer attestation from operational processes, then a policy proposal ought to be brought forth so we can see if there is appetite for removing officer attestation from the NRPM as well. -r -------------- next part -------------- An HTML attachment was scrubbed... URL: From mike at iptrading.com Tue Aug 3 17:25:15 2021 From: mike at iptrading.com (Mike Burns) Date: Tue, 3 Aug 2021 17:25:15 -0400 Subject: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement In-Reply-To: <6A3AF36B-E071-4C64-91E8-D5FBB1936E6E@gmail.com> References: <98342EF6-685B-4341-8788-20F30922C842@arin.net> <6A3AF36B-E071-4C64-91E8-D5FBB1936E6E@gmail.com> Message-ID: <015701d788ae$0d7298a0$2857c9e0$@iptrading.com> +1 to Scott's comments. Mike Burns -----Original Message----- From: ARIN-consult On Behalf Of Scott Leibrand Sent: Tuesday, August 03, 2021 12:21 PM To: John Curran Cc: arin-consult at arin.net Subject: Re: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement I support removal of the attestation requirement. It has now outlived its original purpose, and likely wouldn?t pass a cost-benefit test if proposed today. Scott > On Aug 3, 2021, at 7:15 AM, John Curran wrote: > > ?On 3 Aug 2021, at 9:47 AM, Rob Seastrom wrote: >>>> On Aug 3, 2021, at 8:13 AM, ARIN wrote: >>> ... conditions have changed since this requirement was established, and ARIN believes that the Officer Attestation for resource request tickets is no longer necessary for the following reasons: >>> >>> - Today IPv4 resources are issued by ARIN predominantly via the Waitlist policy, and this policy has been revised to only allow one small request per party (thus avoiding the original risk of ?hoarding? via large suspect requests prior to runout). >> >> To what degree did the requirement for officer attestation contribute to ARIN staff smoking out the abuse of the waitlist that resulted in the revision of the policy a couple of years back? > > Officer attestation did not contribute to the detection - by > definition, the parties who utilized the waitlist were requests whose > need assessment supporting documentation was attested to and then > approved. (One can theorize that even large requests would have been > made absent such attestations but that would be purely conjecture.) > >> Is there any kind of downside in terms of getting law enforcement involved for fraudulent requests if we get rid of this requirement? That is to say, does LE view the application differently with vs. without the officer attestation when evaluating whether there was an act that they're going to use scarce prosecutorial resources on? Interested in Counsel's take on this. > > The proposed change has been reviewed with ARIN?s legal counsel prior to recommendation to the community. As a person intimately familiar with the prosecution of fraudulent requests here at ARIN, I can say that the change to drop attestation of needs-request documentation should not materially affect our anti-fraud processing. > >> ... >> I have never been wholly in favor of requiring an officer attestation for resources for which there is no scarcity/hoarding incentive (i.e. IPv6 blocks and 32 bit ASNs). For those resources I agree that the administrative burden significantly exceeds any potential upside. > > It is true that the change regarding attestation for IPv4 blocks is enabled as a result of being post-depletion with ARIN issuance per the waitlist being of very modestly-sized IPv4 blocks. Under such circumstances the officer attestation is a lengthy delay to certify information which is rather routine in both information and scope. > >> For IPv4 number resources, my position requires some more thought and am eagerly anticipating more community input. > > Acknowledged (and thanks!) > /John > > John Curran > President and CEO > American Registry for Internet Numbers > > > > _______________________________________________ > ARIN-Consult > You are receiving this message because you are subscribed to the ARIN > Consult Mailing List (ARIN-consult at arin.net). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-consult Please contact > the ARIN Member Services Help Desk at info at arin.net if you experience any issues. _______________________________________________ ARIN-Consult You are receiving this message because you are subscribed to the ARIN Consult Mailing List (ARIN-consult at arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN Member Services Help Desk at info at arin.net if you experience any issues. From owen at delong.com Tue Aug 3 19:41:37 2021 From: owen at delong.com (Owen DeLong) Date: Tue, 3 Aug 2021 16:41:37 -0700 Subject: FYI - Proposed process change at ARIN for some request tickets (was: Fwd: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement) In-Reply-To: <4DBE13F4-EA7E-4C98-AA22-CC1CBCA12519@arin.net> References: <0E93A587-E9FC-47F6-8554-2B0C681BE92F@arin.net> <4DBE13F4-EA7E-4C98-AA22-CC1CBCA12519@arin.net> Message-ID: <2F3E729B-00A7-4517-B0C9-4D8F366EBA9D@delong.com> > On Aug 3, 2021, at 05:56 , John Curran wrote: > > NANOGers - > > The following process change is being proposed in order to simplify customer request tickers for new number resources and improve overall service. > > If you have strong feelings one way or the other, thenplease join the arin-consult list and make them known. (Note - the arin-consult mailing list is open to all in accordance with ARIN?s Mailing List AUP and Standards of Behavior.) > > Thanks! > /John > > John Curran > President and CEO > American Registry for Internet Numbers > >> Begin forwarded message: >> >> From: ARIN > >> Subject: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement >> Date: 3 August 2021 at 8:13:53 AM EDT >> To: > >> >> ARIN regularly reviews existing processes as part of our continual improvement efforts to be more responsive and improve the service our customers receive from ARIN. Recently ARIN reviewed the Officer Attestation process and as a result of that review have determined the Officer Attestation process is no longer necessary for achievement of its original goals and should be retired. The purpose of this consultation is to review this proposed change with the community prior to its implementation. >> >> The Officer Attestation was introduced in 2007 in preparation for the depletion of IPv4 addresses. Currently, ARIN requires an Officer Attestation for all requests that involve a needs analysis (which today consist of waiting list requests, NRPM 4.4 micro-allocations, NRPM 4.10 IPv6 transition, IPv6 requests, and transfer recipient requests.) >> >> However, conditions have changed since this requirement was established, and ARIN believes that the Officer Attestation for resource request tickets is no longer necessary for the following reasons: >> >> - Today IPv4 resources are issued by ARIN predominantly via the Waitlist policy, and this policy has been revised to only allow one small request per party (thus avoiding the original risk of ?hoarding? via large suspect requests prior to runout). Correct me if I am wrong, John, but I believe this is one small request per party at a time, not for all time. (e.g. unlike APNIC?s original final /22 per member policy for their last /8, ARIN does allow an organization to apply to the waitlist, receive addresses, then upon utilization of those addresses apply to the waitlist again). >> - With regard to transfers of IPv4 resources obtained via the transfer market, the inherent costs for large transfers ensures organizational officers are ?in the know?. >> - Given IPv6 availability, officer attestation of need for IPv6 resources is not necessary. Interesting reversal. I argued when officer attestation was first introduced that applying it to IPv6 was silly and you were among those expressing skepticism. What brings about this change of heart? IPv6 is certainly no more plentiful today than it was back then. >> The review identified that at this point in time the Officer Attestation process is problematic for many customers, predominantly posing an administrative burden that does not materially improve policy implementation and resulting in numerous complaints and adding unnecessary delay (varying between two days and an entire week) to completion of resource request tickets. It?s a small administrative burden, but despite processing requests for many clients of a variety of sizes and assisting many other clients of significant size in handling their own requests, I have not encountered a single environment where I would call it ?problematic?. I have always felt that it did not materially improve policy implementation with regard to IPv6 and I stand by that sentiment. I remain unconvinced that it is unimportant for IPv4, despite the escalating costs of IPv4 addresses. >> In light of the administrative burden to customers and undefined benefit, ARIN proposes dropping the Officer Attestation requirement ? note that this specifically does not change documentation requirements related organization recovery of IP number resources or related anti-fraud measures that ARIN has implemented. I think removing this requirement for IPv4 is premature at best. I think removing this requirement for IPv6 is long overdue as it has never served a policy purpose. Owen >> >> This consultation will remain open for 10 days. >> >> Please provide comments to arin-consult at arin.net . You can subscribe to this mailing list at: http://lists.arin.net/mailman/listinfo/arin-consult . >> >> Discussion on arin-consult at arin.net will close on 13 August 2021. >> >> Regards, >> >> John Curran >> President and CEO >> American Registry for Internet Numbers (ARIN) >> >> _______________________________________________ >> ARIN-Consult >> You are receiving this message because you are subscribed to the ARIN Consult Mailing >> List (ARIN-consult at arin.net ). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-consult Please contact the ARIN Member Services >> Help Desk at info at arin.net if you experience any issues. > -------------- next part -------------- An HTML attachment was scrubbed... URL: From jcurran at arin.net Tue Aug 3 19:55:01 2021 From: jcurran at arin.net (John Curran) Date: Tue, 3 Aug 2021 23:55:01 +0000 Subject: [ARIN-consult] FYI - Proposed process change at ARIN for some request tickets (was: Fwd: Consultation on Retiring the Officer Attestation Requirement) In-Reply-To: <2F3E729B-00A7-4517-B0C9-4D8F366EBA9D@delong.com> References: <0E93A587-E9FC-47F6-8554-2B0C681BE92F@arin.net> <4DBE13F4-EA7E-4C98-AA22-CC1CBCA12519@arin.net> <2F3E729B-00A7-4517-B0C9-4D8F366EBA9D@delong.com> Message-ID: On 3 Aug 2021, at 7:41 PM, Owen DeLong > wrote: - Today IPv4 resources are issued by ARIN predominantly via the Waitlist policy, and this policy has been revised to only allow one small request per party (thus avoiding the original risk of ?hoarding? via large suspect requests prior to runout). Correct me if I am wrong, John, but I believe this is one small request per party at a time, not for all time. (e.g. unlike APNIC?s original final /22 per member policy for their last /8, ARIN does allow an organization to apply to the waitlist, receive addresses, then upon utilization of those addresses apply to the waitlist again). Owen - That is correct, but the total resource limit and holding requirements means that we do not see many repeat applicants (and those who do are limited in the maximum resources that are obtainable.) The review identified that at this point in time the Officer Attestation process is problematic for many customers, predominantly posing an administrative burden that does not materially improve policy implementation and resulting in numerous complaints and adding unnecessary delay (varying between two days and an entire week) to completion of resource request tickets. It?s a small administrative burden, but despite processing requests for many clients of a variety of sizes and assisting many other clients of significant size in handling their own requests, I have not encountered a single environment where I would call it ?problematic?. I have always felt that it did not materially improve policy implementation with regard to IPv6 and I stand by that sentiment. I remain unconvinced that it is unimportant for IPv4, despite the escalating costs of IPv4 addresses. In light of the administrative burden to customers and undefined benefit, ARIN proposes dropping the Officer Attestation requirement ? note that this specifically does not change documentation requirements related organization recovery of IP number resources or related anti-fraud measures that ARIN has implemented. I think removing this requirement for IPv4 is premature at best. I think removing this requirement for IPv6 is long overdue as it has never served a policy purpose. Good to know - thanks for participating in the consultation! /John John Curran President and CEO American Registry for Internet Numbers -------------- next part -------------- An HTML attachment was scrubbed... URL: From info at arin.net Mon Aug 16 11:49:27 2021 From: info at arin.net (ARIN) Date: Mon, 16 Aug 2021 11:49:27 -0400 Subject: [ARIN-consult] =?utf-8?q?ACSP_Consultation_2021=2E4_=E2=80=93_Re?= =?utf-8?q?tiring_the_Officer_Attestation_Requirement_is_Now_Closed?= Message-ID: ARIN thanks those who provided valuable feedback during this consultation on retiring the Officer Attestation requirement for all requests that involve a needs analysis (which today consist of waiting list requests, NRPM 4.4 micro-allocations, NRPM 4.10 IPv6 transition, IPv6 requests, and transfer recipient requests.) We appreciate the feedback from the community on this consultation and would like to highlight a few topics from that conversation in closing: -??This proposed change was reviewed with ARIN?s legal counsel prior to opening the consultation, and the change to drop officer attestation of needs-request documentation should not materially affect our anti-fraud processing. - The proposed change to officer attestation is only for needs-assessment document requests and would not affect circumstances specified in the Number Resource Policy Manual (NRPM). With these clarifications, we were able to confirm sufficient support of the community participants to this change, and we intend to move forward with the immediate retirement of the Officer Attestation requirement for requests that involve needs analysis as described above. Thank you again to those who provided valuable feedback on this consultation. Regards, John Curran President and CEO American Registry for Internet Numbers (ARIN)