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Re: [Nro-comments] ETNO comments on Proposed Open Letter to ICANN
Dear Leo Debecker,
Thank you for your comment on behalf of ETNO.
Firstly, we recognize that the intentions with the clause in 6.1 on the
Executive Council ratifying or rejecting policy may seem inappropriate when
taken out of context. Accordingly, we will add the following text:
"Such decisions shall be based on open and transparent procedures which are
ratified by the regional address policy fora."
As explained in other responses the intention is that any decision on global
policy would only take place in the (probably unlikely) situation that there
is no MoU with ICANN. In this case the Executive Committee would take the
proposed role of ICANN to perform a formal verification whether the
appropriate procedures had been followed in development of the policy.
While out of context the NRO might seem to describe an organization that
both develops and ratifies policy, the reality is that policies are
developed in the open regional internet address working groups and fora,
then a certain work is done by the working groups assisted by the RIRs to
harmonize policies where required, next the ASO, or NRO Address Council will
verify that processes were followed and perform an additional public
hearing, and finally ICANN, or in case of ICANN failure, the NRO Executive
Committee would make a final assessment.
best regards/
Frode Greisen, RIPE NCC executive board member
On 22/10/03 18:52, "Debecker Leo" wrote:
> 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
>
>
>
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> 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
>
>
>
>
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> ETNO Expert Contribution EC053 (2003/10)
>
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>
