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To all RIR Boards,
Please find below ETNO’s views on the Proposed Open Letter to ICANN from the Regional Internet Registries. ETNO’s position paper takes the form of an Expert Contribution which was unanimously agreed by all the members of the ETNO Naming, Addressing and Numbering Working Group and was endorsed by the ETNO Board. The paper will equally be published, as of tomorrow, on our web site at: www.etno.be
Best regards,
Leo Debecker Executive Manager, Operations ETNO Brussels.
October 2003
ETNO Expert Contribution on ICANN reform
Executive Summary
ETNO welcomes the initiative of the Regional Internet Registries (RIRs) to reinforce their collaboration through a new structure (NRO). But ETNO would like to see further clarification concerning the draft agreement between RIRs, in order to clearly understand the differentiation between operational activities and policy development. In ETNO's view, policy issues should not fall under the responsibility of the NRO structure to avoid any conflict of interest.
As part of the address community, ETNO (1) appreciates the opportunity offered to comment on the Regional Internet Registries (RIR) draft for public comment on ICANN reform, published on 23rd September 2003.
In their draft open letter to ICANN, ETNO notes that “the RIRs acknowledge the benefits of the ICANN structure in terms of providing an open framework for the coordination of a number of critical Internet administration functions, and have determined that they will continue to work within this framework and support ICANN in this endeavour”.
ETNO is satisfied with the intention of the RIRs to reinforce their collaboration.
These intentions constitute a positive evolution in the reinforcement of the stability and coherence of IP address management, and ETNO supports these initiatives.
Our in-depth analysis of the draft agreement between RIRs, however, raises some questions that demand further clarification.
1. The Number Resource Organisation seems to be a structure mixing operational activities and policy development. These two different activities need a clear distinction in order to avoid conflicting interests. A good way around this would be to restrict the NRO to non-policy issues (technical cooperation between RIRs, service contracts, etc., and to have an ASO council, distinct from the NRO organisation with a clear responsibility on policy issues.
2. “The NRO Executive Council shall ratify or reject proposed global IP number resource policies and the NRO Number Council shall be responsible for the provision of advice on such proposed policies”. According to the proposed selection process, the NRO Executive Council is selected by the RIRs Board, and cannot be representative of the addressing community as a whole. ETNO is of the opinion that a ratification of a policy proposal or even an involvement of this Council in the policy development process is inappropriate.
ETNO suggests that this task should be organised under the responsibility of the ASO council. In order avoid any conflict of interest, it is essential that no member of the ASO council be an employee or a Board member of an RIR.
Regarding the Global Policy Development Process, ETNO considers that the appropriate body to ratify a consensus position (Step 4) is the ASO Address Council and not the Boards of the RIRs.
In the same way, the appropriate body for consultation by the ICANN Board (Step 8 to 12) should be the ASO Address Council, and not the RIRs.
--------------------- (1) The European Telecommunications Network Operators' Association, is representing 39 major companies from 34 European countries, providing electronic communications networks over fixed, mobile or personal communications systems. ETNO's primary purpose is to establish a constructive dialogue between its member companies and actors involved in the development of the European Information Society to the benefit of users. More information on ETNO can be found at : www.etno.be
ETNO Expert Contribution EC053 (2003/10)
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