Re: FYI - Proposed process change at ARIN for some request tickets (was: Fwd: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement)

[Owen DeLong via NANOG <nanog () nanog org>]

> On Aug 3, 2021, at 05:56 , John Curran <jcurran () arin net> 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 <info () arin net <mailto:info () arin net>>
> > Subject: [ARIN-consult] Consultation on Retiring the Officer Attestation Requirement
> > Date: 3 August 2021 at 8:13:53 AM EDT
> > To: <arin-consult () arin net <mailto:arin-consult () 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).

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 () arin net <mailto:arin-consult () arin net>. You can subscribe to this 
> > mailing list at: http://lists.arin.net/mailman/listinfo/arin-consult 
> > <http://lists.arin.net/mailman/listinfo/arin-consult>.
> >
> > Discussion on arin-consult () arin net <mailto:arin-consult () arin net> will close on 13 August 2021.
> >
> > Regards,
> >
> > John Curran
> > President and CEO
> > American Registry for Internet Numbers (ARIN)
> >
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