Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
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Please share any additional comments you have on this principle:
The voting threshold may need to be fully fleshed out. If we assume for argument’s sake that there are 4 RIRs, and the to-be- derecognized RIR is represented on the NRO EC, if one RIR abstains, and the remaining vote in favour, with a 50% vote, “does the motion pass?” (or if one is incapacitated)
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Can we consider a scenario where a "practice" within an RIR triggers a change in ICP2?
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We assume that “large” should not be such that the policy “may be gamed” to enable the creation of a country-specific RIR. There should also be consensus within the Region that is impacted.
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Maybe “2 to be considered for recognition as an RIR”, rather than “to be recognized as an RIR”
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The ISPCP notes that in the context of an audit, a “broad support” may be difficult to assess, if the means to make this assessment is not specified.
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How is it substantiated? What are the metrics?
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The ISPCP notes that “corporate governance best practices” may vary region the region covered by a RIR, and best practices and legislations may even be incompatible between countries (eg one tier vs two tier models of corporate governance, financial reporting standards, mandatory board committees on the board etc). The legal corporate governance provisions of the country/jurisdiction where the RIR is incorporated will have to be met.
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If only “a majority” of an RIR’s governing body (eg a Board) must be elected by its own members, how is the rest determined and what does it mean? (would they be independent directors? Under what appointment procedure?) Election procedures and term limitations must be predetermined for both elected and independent directors.
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The application of the policies should also be documented, transparent, and to the extent possible publicly recorded.
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Should there be a requirement on their frequency, possibly the nature/metrics to be looked at or how regular those audits are?
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Shouldn’t there be a reference to those allocations being made according to policies that have been approved through the PDP?
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To the extent possible, it may be desirable for this support to be done in a documented and transparent manner.
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We are uncertain this principle can be enforced in the event an RIR is derecognized “without its consent”, whether such as scenario is likely, and whether it is desirable to cover such a scenario. Maybe a ‘should’ rather than a ‘must’ would be achievable in this respect.
The Internet Service Providers and Connectivity Providers Constituency thanks the ASO for the opportunity to comment on the proposed update to Internet Coordination Policy 2 (ICP-2) Principles and offers the following comments.
The Consistency also understands that these principles are intended to be generic. Without the details of the extensive work that lead to these draft principles as they are presented to the community, the Constituency offers these comments in good faith, mindful that the question raised might have been considered, and it is not the intention of the Constituency to reopen these discussions if the ASO considers that consensus has been reached on the matter at hand.
These comments will be posted on behalf of the ISPCP on ICANN’s Public Comments webpage.
General comments:
1) To this day, the RIRs engagement with ICANN has been limited to a narrow set of questions where global coordination is essential and much was left to for bottom-up coordination within the Region and between the RIRs themselves, with limited top-down authority. The revised policy would appear to flip the chain of authority upside down with the critical decision of recognition and derecognition made by the NRO, thereby turning the informal RIR CEO coordination into a potentially more formal decision-making body.
Mindful that the revised policy results from a need for a more robust and formal process made even more acute by the situation of AFRINIC, the ISPCP acknowledges that defining criteria for recognising a RIR without such a global governing function may not be achievable. However, much will depend on the future conditions to be met by a ‘recognisable RIR’, and we are of the view that these conditions should be kept to a bare minimum and not overly affect existing RIRs. In addition, if such an authority were bestowed, it cannot go without its guardrails and appropriate accounting mechanisms.
2) There seems to be three distinct sets of principles laid out in the updated policy:
o The criteria that a candidate RIR would have to meet to be recognised: 6, 7, 8, 9, 10
o General principles that apply to all RIRs and not only the candidate RIR: 3, 4, 5, 11, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22
o the procedure that is used between all existing RIRs for a recognition: 1, 2, 23, 24
In this respect, the condition that a candidate RIR has to meet all principles including this third category may not seem quite right. For example, what does it mean for a candidate RIR to be compliant with 1, 2 or 23?
3) We are aware of an IETF pre-WG activity (https://datatracker.ietf.org/group/deepspace/about/) that contemplates IP prefix allocation for non-terrestrial networks, and implicitly discusses which RIR might be responsible for this. We would assume ICP2 to be applicable in context, but the question is worthwhile considering in the next steps of the review of ICP2.
4) It would be interesting to “stress test” the revised ICP2 with several scenarios (including 3) or lessons learnt from what happened – or what could have happened – with AFRINIC possibly, if this policy had been applied)