[ARIN-consult] Consultation on Retiring the Officer Attestation Requirement

[ARIN]

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)