RE: [Nro-comments] A Concern on the Process Used to Consider the NRO documents

["Ray Plzak" <plzak@arin.net>]

Mark,

Below by means of annotation are comments regarding your concerns.

Ray Plzak
ARIN Board Member

**************************************

Thank you for yout statement of concern relating to the process used to
consider the NRO documents

Following careful consideration of your note, it appears that your
concerns basically rest on the assertion you make that:

    "I think that the NRO proposal has wide-ranging, long-lasting
impacts on the
     technical coordination, planning and administration of addressing
and
     numbering policy.  I've found it difficult to find anyone would
disagree
     with that assertion."

This is broad assertion and one that requires closer inspection. 

In terms of the development of addressing and numbering policy, the NRO
does not alter the fundamental proposition that address and numbering
policies are developed  within the affected communities (the so-called
"bottom-up" policy development process).  Some of these policies can be
implemented within the domain of the RIRs, while some require
coordinated
action by all RIRs and also require some action on the part of a third
party.

These latter forms of policies are proposed to be passed to the Number
Council of the NRO for review and consideration. Within the context of
an
agreement with ICANN the intended steps are for the Number Council to
satisfy itself that the proposed policy meets certain criteria (as
described in the draft ASO MoU) and then to forward it to the Board of
ICANN for adoption as a global policy. In a "stand alone" context where
there is no ICANN, the Number Council performs the same role, and the
NRO
Executive Council undertakes formal ratification of the  proposed
policy,
acting on the advice of the Number Council.

The integrity of the RIR's own policy development processes are not
altered or compromised in any way within the context of the NRO, and
from
this perspective the only impact on the policy development could be
considered further support of the existing bottom-up process.

The RIR's task is to undertake administration of the Internet's number
resources in accordance with relevant policy. The a small part of this
administrative task requires the coordination of joint activity across
all
RIRs. The NRO provides an organizational structure to host this existing
joint activity.To the extent that it facilitates such joint activities,
this is an intended positive impact of the NRO on the operations of the
RIRs. However it is noted that there is no policy determination role
within the operational scope of the NRO.

There is a distinction between processes and procedures used to
formulate
policy, and structures and mechanisms used to administer a resource in
accordance with determined policies. The NRO proposal does not alter the
processes and procedures used within the regional communities for the
formulation of coordinated global policies.

The proposed actions of the NRO Number Council may have a bearing on
this
activity, but the NRO document explicitly calls for the Number Council
to
develop procedures in an open and transparent manner, and there will be
the opportunity for community consideration of any such changes as and
when such procedures are being drafted.

As noted in the draft open letter to ICANN:
(http://www.apnic.net/docs/drafts/draft-nro-proposal-20030923.html)
    "Within this proposed framework the essential elements of
interaction
     between the RIRs and ICANN remain unaltered." 

The material provided in the FAQ on this topic
(http://www.apnic.net/info/faq/nro-faq.html) is a useful summary of this
matter, namely:


- Will the NRO MoU and the ASO MoU have any wide-ranging impacts on
  technical coordination, planning, and administration of addressing and
  numbering policy?

    The NRO MoU and the ASO MoU will have impact in some areas, but it
    will be only to strengthen the protection of the unallocated number
    resource pool and the bottom up policy process.

    Areas not changed:
    
    . The bottom up policy process from the addressing community to the
      RIR fora will not change.

    . The bottom up policy process for global policy from the addressing
      community to the ASO AC will not change.

    . The administration of policy between the RIRs and the community in
        their respective service regions will not change.

    . The administration of addressing policy between the IANA and the
      RIRs will not change.

    Areas that will change under these proposals:

    . The ICANN board will not be able to make and direct top down
      addressing policy.

    . The ICANN board will not be able to veto a global policy proposal
by
      direct or indirect means.

    . Activities where the RIRs act in concert will be strengthened by
the
      formalizing of an already existing relationship. This will occur
in
      such areas as policy harmonization, technical coordination, and
      planning.

    . Activities such as technical coordination and administration of
      policy where the IANA must interact jointly with the RIRs will be
      simplified as the IANA will now have a single interface point.

 
- Will these documents will have long-lasting effects?

    It is hoped that this is indeed the case. It is the intent of these
    documents to put into place provisions that will protect the
    unallocated number resource pool and the bottom up policy process
thus
    contributing directly to the security and stability of the Internet
    for years to come. It is expected that as the Internet environment
    changes over time that these documents may have to be revised, thus
it
    is expected that they will be reviewed from time to time.