[Nro-comments] TR: NRO proposal

["BIDRON Alain RO/DSA" <alain.bidron@francetelecom.com>]

Dear all,
I’ve read the proposals from the RIR Boards to create a Number Resource Organization.
I’ve also read previous comments on this mailing list and responses from RIRs Board members.

I think that during the last years, the RIRs have deployed an impressive energy to collaborate between them, for the clear and real benefit of all stakeholders.
Their intention to go further through a new structure is a good way in order to improve the stability, consistency and efficiency of number management, and I support this initiative.

Regarding policy development, it is fundamental to stick to basic principles of bottom up, transparent and open process, avoiding any potential bottleneck.
Otherwise, the current system would be subject to legitimate criticism and considerably weakened.

The NRO is, as I understand an operational collaborative structure between the RIRs, and a structure “to act collectively on matters to the interests of the RIRs”.
As a consequence, this structure cannot be involved in the policy development process, even in the hypothetical situation of a failure of ICANN. Otherwise, RIRs staff or Board member would be in a situation to approve or reject policy they have to apply.
A clear division between operational/executive and policy development and approval/legislative is needed, and is not reflected in the proposal.
The body responsible for the provision of advice on policy issues (Number council) has to be independent of the NRO Executive Council, and the NRO Executive Council as it is proposed, is not the appropriate body to approve or reject any policy.
If the appointment by the Board of each of the RIRs of a member of the Number council is an acceptable solution, , this member should not be staff member or Board member of any RIR in order to avoid any conflict of interest.
Operational feasibility of a policy proposal has to be analyzed, during the consultative process within the regional communities and not at the final stage of approval.
 
Regarding the operational or external activities to be undertaken by the NRO, it would be useful to define the scope of those activities.
Regarding the incorporation of the structure, law and location is an important issue and need to be clarified.
Best regards.