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[Nro-comments] Comments of the ASO AC on NRO documents



ICANN Address Supporting Organization
ASO Address Council

To:		Regional Registries CEO
		NRO-comment mailing list

From: 	ASO Address Council

RE: 		Comments and concerns regarding the NRO formation proposal
documents

On October 15th the ASO Address Council met to discuss the documents
published by the RIRs in September.

The Address Council recognizes and appreciates the hard work and thoughtful
attention to detail that is present in all three documents (letter to the
ICANN Board, the proposed NRO formation document, and the draft MoU on the
ASO and AC).  In our teleconference we focused on the proposal for a Number
Resource Organization.  We hope our comments and suggestions prove useful to
you as you create a final letter and plan for implementing the Number
Resource Organization.

PUBLIC INPUT TO THE PROPOSAL
While the process ending up in this concrete proposal has been going on for
a long time, and has been open to comments and discussion, the concrete
proposal describing the NRO could benefit from discussion at the upcoming
RIR meetings. While formally the creation of the NRO may be within the
jurisdiction if the RIR boards the RIR tradition has previously been to
consult its membership on such important changes. A strong bottom up support
for the proposal would strengthen the legitimacy of the proposal.

TRANSPARENCY IN THE EXECUTIVE COUNCIL
We believe that those drafting the NRO documents paid careful attention to
the need for open and transparent processes in NRO activities.  As an
example, the NRO Number Council is specifically required to ". . . develop
procedures in an accessible, open, transparent and documented manner for
conducting business in support of their responsibilities . . ."  The Address
Council believes this is an essential feature of fair process for all
involved in the addressing and numbering community.

We are unable to find a similar requirement for the NRO Executive Council.
We believe that there should be a statement on openness and transparency
regarding the Executive Council.  The text in section six of the NRO
formation document should be amended to clarify this point. This would
emphasis the importance of openness and transparency at all levels in the
organization.

RATIFICATION AND REJECTION OF POLICY
The Address Council notes that in section 6a) of the proposed NRO agreement,
it states that the NRO Executive Council can ratify or reject global IP
number policies.  We spent a substantial amount of time attempting to
understand when and how the Executive Council would exercise this authority.

During this discussion it was suggested that it may help if section is 6a)
clarified to state that the policies ratified by the NRO Executive Council
would be based on member decisions in each RIR region.

It is also recommended that a statement is added to this section of the
agreement which states that policies must be developed following bottom-up,
open and transparent processes stated as in the, to-be-negotiated, MoU with
ICANN. 

APPEALS ADVISORY PROCESS
The Address Council believes that the authority of the Appeals Panel is not
clear.  If advice has been given by the NRO Advisory Appeals Panel, what (if
any) obligations are upon the RIRs to act according to that advice?

The Address Council would like language in section 9) of the NRO formation
document that makes clear what obligations - if there are any - the RIRs are
under in the unlikely event that an Advisory Appeal Panel finds that an RIR,
NRO or NRO suborganization fails to follow its own documented processes.

RELATIONSHIP BETWEEN NRO NC AND ICANN
In the proposed MoU between the NRO and ICANN, within section 3) and in
bullet point 4, there is a statement about the responsibility of the future
Address Council:

"providing advice to the Board of ICANN on number resource allocation
policy, in conjunction with the RIRs"

Members of the Address Council suggest that the meaning of the language "in
conjunction with the RIRs" is clarified to highlight the positive working
relationship of all the entities involved.

SUMMARY
The Address Council appreciates the hard work of the many people that
contributed to the published draft of these documents.  The establishment of
the NRO creates a single point of contact for ICANN and a mechanism to
formalize the coordination of global IP number resources.  We believe that
these will be long-lasting and positive contributions to the community.

Attachment: ICANN ASO AC - Statement on NRO Formation - Final.pdf
Description: Adobe PDF document