Re: [Nro-comments] Isn't one ICANN more than enough?

["L. Gallegos" <jandl@wecn.net>]

On the surface, the idea of formalizing the relationship among the 
four RIR's is an ecouraging development.

These are my concerns.

1. Where is the input from the greater community to be made and 
who, under the policies of the NRO, is the community?

     As a user who has a subnet assigned, it is a concern that 
     allocation of IP addresses be fairly implemented across the 
     board.  Therefore, those, like me, who rely upon the availability 
     of IP addresses, need assurance that they are obtainable with 
     reasonable justification (define reasonable).  For example, the 
     need for unique addresses for secure site certs.

     The RIR's have thus far seemingly done a good job with 
     allocation, but where are the safeguards if  policies should 
     change in the same manner that ICANN policies have to the 
     detriment of users?  There is potentially a far greater danger to 
     the internet from the RIR's if this should occur and there is no 
     oversight or influence of the community itself.  

     With this proposed agreement, the RIR's would protect 
     themselves, but not the community (see quote below).

     Quote:     "Serving as the coordinating mechanism of the RIRs 
     to act collectively on matters relating to the interests of the 
     RIRs, as delegated to the NRO by the unanimous written 
     agreement of the RIRs..."

2.  In the event of the failure of ICANN (not a bad thing, IMO), how 
would the NRO incorporate the IANA role of maintaining the root 
and should this IANA function be under the same organization as 
the numbering authority?

     In my mind, the IANA root function should be separated from 
     the numbering authority, and all of it totally separate from 
     ICANN.  ICANN has a conflict of interest in these areas.  I would 
     like to see some discussion of these functions as they relate to 
     the RIR's.

3.  Expansion to an additional layer will incur costs that will be 
passed on to the community.  How is this justified?  Costs for 
allocation of IPs is already higher than necessary.  Please justify 
these charges.  Should the community have to pay for increased 
levels of beaurocracy and will this not penalize those countries and 
communities who can ill afford it?  

     The NRO has been proposed by the RIR's, not the community.  
     If the community is going to fund it one way or the other, 
     approval should come from the community and not the just the 
     RIR's.  

The address allocation function is critical to the operation of the 
internet as we know it and the RIR's have shown an understanding 
of this responsibility, but where is the oversight in case of abuse or 
capture by special interests - as has been evident in ICANN?  The 
global community can ill afford capture, so an answer to this 
question is also critical.  Every arbitrary decision made by the RIR's 
has the potential to dessimate any given community on the 
internet.

I look forward to responses.

L. Gallegos