ACSP Consultation 2021.4: Retiring the Officer Attestation Requirement

Consultation Tracking Information

  • Requested By: Staff
  • Status: Closed
  • Comments Opened: Linked to Discussion Archives: 03 August 2021
  • Comments Closed: 13 August 2021
  • Suggestion Number: n/a

Consultation Description

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@arin.net. You can subscribe to this mailing list at: http://lists.arin.net/mailman/listinfo/arin-consult.

Discussion on arin-consult@arin.net will close on 13 August 2021.

ARIN Actions

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.

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