[arin-ppml] Draft Policy ARIN-2022-3: Remove Officer Attestation Requirement for 8.5.5

[Matthew Wilder]

Hi Noah, et al.

It appears that a few of you are not convinced of the problem statement for
this Draft policy. Just a reminder this is a draft policy authored by the
Policy Experience Working Group, to solve a customer experience problem
identified by staff. Also, taking off my AC hat and putting on my day job
hat for a moment - I can assure you that if you are at an organization of
significant scale and complexity - this is indeed a real problem. In the
case of qualification for transfers (8.5.5) this is a redundant step, in
practice, since significant sums of money must be approved by executives in
order to execute transfers.

Swapping back to my AC hat now. To my mind, the introduction of officer
attestations generally helped achieve two positive outcomes. First, it
supported the principle of conservation. Second, it reduced the opportunity
for fraud. There may be other benefits obtained by the requirement for
officer attestation, and I am open to hearing everyone's perspective on
this.

This draft policy would do away with the need for officer attestation for
justification of transfers, but only because the market provides the same
benefits mentioned above. Would-be fraudsters on the transfer market would
now face significant cost to execute a transfer, and presumably, an
organization operating in bad faith could easily provide officer
attestation. Similarly, documentation of an overly-optimistic plan -
securing more resources than realistically needed - will mean a higher cost
to the organization bankrolling the transfer. As a result, the individuals
accountable for the organization's decisions are well aware of - and
implicitly supportive of - the plan. An officer attestation is therefore
redundant in both cases.

To Noah and others who have voiced opposition - let me know if you see a
case where the officer attestation in 8.5.5 protects the interests of ARIN
and the community.

Best regards,
Matthew



On Tue, Jun 21, 2022 at 9:15 PM Noah <noah at neo.co.tz> wrote:

>
>
> On Wed, 22 Jun 2022, 04:56 ARIN, <info at arin.net> wrote:
>
>> On 16 June 2022, the ARIN Advisory Council (AC) accepted "ARIN-prop-309:
>> Remove Officer Attestation Requirement for 8.5.5" as a Draft Policy.
>>
>> Draft Policy ARIN-2022-3: Remove officer attestation requirement for 8.5.5
>>
>> Problem Statement:
>>
>> Requiring an officer attestation requires unnecessary resources and
>> increases the time to complete an IPv4 transfer.
>>
>>
>>
>> Policy statement:
>>
>>
>>
>> 8.5.5. Block Size
>>
>>
>>
>> Organizations may qualify for the transfer of a larger initial block, or
>> an additional block, by providing documentation to ARIN which details the
>> use of at least 50% of the requested IPv4 block size within 24 months.
>>
>>
>>
>> Removing “An officer of the organization shall attest to the
>> documentation provided to ARIN.
>>
> Using time as an excuse does not fly. Attestation is accountability and
> enforces legitimacy.
>
> An authorized officer should not only be aware but MUST also be involved
> in attesting of documents that involve any Internet Number Resources
> transfers.
>
> We have experienced fast hand on the negative impact of Admin Contacts
> being clueless to what its that Tech contacts do.
>
> So I oppose the policy for using time as an excuse to remove an important
> process that ensures legitimacy.
>
> Noah
>
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-- 

*Matthew Wilder*

Sr Engineer - IPv6, IP Address Management
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