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



Hi,

Thanks for your thoughtful comments. I've interleaved a response between
each of your comments:

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

The essential observation here is that  nothing has changed in the RIR's
own policy process, nor has anything changed in the relationship between
the regional open policy forums and the RIR. The same bottom-up process of
self-regulatory mechanisms still apply and the risk stated in your comment
- that some inappropriate policy is imposed on the community - is not
facilitated, or even contemplated in this NRO structure.  Protection of
the community's interests is implemented through the same structures as we
have today: through the community engaging directly in the process of
policy determination within each region using RIR-hosted services to do
so.

> 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?

The safeguards mentioned in the cover letter refer specifically to the
IANA function of number resource administration. It is not envisaged that
this organization would be properly structured to undertake any form of
function of administration of the root name system, nor is it considered
appropriate that this option be pursued. The NRO is not being structured
as a potential 'complete' ICANN replacement in the event of failure of
ICANN. The consideration here was that in such an event it was considered
probable that the various IANA functions would be undertaken by those with
a direct interest in each particular functional area. So, no it is not
envisaged that in such an eventuality that root management function would
be operated by the NRO.


> 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 proposed functions of the NRO are in most cases, currently being
undertaken by the RIRs under the terms of the existing ASO MoU with ICANN,
and in the remainder of the cases are already undertaken on an informal
basis between the RIRs. The NRO provides a visible framework for this
existing cooperative joint activity while not adding any significant
additional cost overheads to the RIR's operational environment.

> 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.


The issues surrounding capture are of course serious concerns. As noted
above, the NRO in no way alters the ability of the RIRs and the
communities they serve to operate with integrity. The checks and balances
within each RIR's environment of operation are unaltered. In the case of
NRO actions, these concern global policies. As noted in the documents,
such global policies are those which require the actions of an external
body (such as ICANN) in order to be implemented. The proposed processes
used within the NRO in relation to such policies are intended to ensure
that RIRs followed their own documented processes in reaching agreement
with the proposed policy, and then undertaking a wider call for comment
from the community to ensure that significant views have been considered
in the formulation of the policy. It is considered that this provides the
community with assurances that there are checks and balances and
mechanisms to ensure that procedures are followed correctly and that all
significant viewpoints from interested parties are considered. Obviously
all this is based on a strong ethos of participation in the RIR- hosted
open policy forums, and it is upon these sound foundations that the
framework proposed here has been based.


Regards,

   Geoff Huston
   APNIC Executive Council Member