Public Comment

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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Name: Registries Stakeholder Group (RySG)
Date: 6 Dec 2024
1) Do you agree with the Authority principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree

Please share any additional comments you have on this principle:

The RySG suggests that when drafting the updated version of the ICP-2 document, the authors are clear about what the term "ICANN" refers to in this context - the ICANN Organization, Board or Community.

2) Do you agree with the Amendment principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree

Please share any additional comments you have on this principle:

The RySG suggests that when drafting the updated version of the ICP-2 document, the authors are clear about what the term "ICANN" refers to in this context - the ICANN Organization, Board or Community.

3) Do you agree with the Rectification principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree
4) Do you agree with the Coverage principle as set forth in the Proposed ICP-2 (v2) Principles document?
Agree

Please share any additional comments you have on this principle:

The RySG suggests that when drafting the updated version of the ICP-2 document, the authors consider how this principle will apply during a potential transition between RIRs. As an example: "… continually receive RIR services, and that the transition of any geographic area between RIRs be planned and managed, so as to avoid unnecessary operational disruption for impacted users."

5) Do you agree with the Service Region principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree

Please share any additional comments you have on this principle:

The Service Region principle does not indicate the resolution mechanism if there is confusion and/or dispute regarding the Service Region of RIRs. The RySG suggests that when drafting the updated version of the ICP-2 document, the authors provide clarification.

6) Do you agree with the Recognition principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree

Please share any additional comments you have on this principle:

The RySG notes that the Recognition principle does not require the RIR to meet the requirements in an auditable fashion, as is required under the Operation Principle. The RySG suggests that when drafting the updated version of the ICP-2 document, the authors consider adding an audit requirement to avoid a newly recognized RIR from quickly being out of compliance.

7) Do you agree with the Operation principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree
8) Do you agree with the Derecognition principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree

Please share any additional comments you have on this principle:

The RySG notes that this principle seems to be in conflict with the Recognition and Operation principles, which require compliance with the ICP-2, while the Derecognition principle only describes that an RIR “may” be derecognized. The RySG suggests that the ASO AC consider whether more specificity regarding the consequences of not meeting the requirements of the ICP-2, including a possible cure period, be added to this principle.

9) Do you agree with the Community Support principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree

Please share any additional comments you have on this principle:

The RySG suggests that the Community Support principle should apply both to a Candidate RIR and an operational RIR. This would clarify that continued community support is required to comply with the ICP-2.

10) Do you agree with the Community Commitment principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree

Please share any additional comments you have on this principle:

The RySG again believes this principle should apply to both Candidate RIRs and existing RIRs to ensure a continued Community Commitment to the RIR beyond its candidate stage.

11) Do you agree with the Independence principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree

Please share any additional comments you have on this principle:

The RySG suggests that when drafting the updated version of the ICP-2 document, the authors consider an additional requirement that the claim of financial stability and independence be verifiable, such as through an independent auditor’s statement.

12) Do you agree with the Not-for-Profit principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree

Please share any additional comments you have on this principle:

The RySG suggests that when drafting the updated version of the ICP-2 document, the authors augment this principle with some qualification of the "not-for-profit basis"; perhaps something similar to "consistent with regulations in its jurisdiction".

13) Do you agree with the Corporate Governance principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree
14) Do you agree with the Member-Controlled principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree
15) Do you agree with the Community-Driven principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree
16) Do you agree with the Neutrality principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree
17) Do you agree with the Transparency principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree
18) Do you agree with the Audit principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree

Please share any additional comments you have on this principle:

The RySG suggests that when drafting the updated version of the ICP-2 document, the authors provide specified time periods for audits conducted pursuant to the Audit principle. Annual audits are typical in business and operational contexts.

19) Do you agree with the Service principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree

Please share any additional comments you have on this principle:

The RySG suggests that when drafting the updated version of the ICP-2 document, the authors add clarity and sources regarding the "standard protocols and specifications" by which RIRs must operate.

20) Do you agree with the Continuity principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree
21) Do you agree with the Anti-Capture principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree

Please share any additional comments you have on this principle:

The RySG notes the ambiguity of the word “capture” and suggests that when drafting the updated version of the ICP-2 document, the authors add clarity to the intended meaning of this term.

22) Do you agree with the Ecosystem Stability principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree
23) Do you agree with the Remedial Bias principle as set forth in the Proposed ICP-2 (v2) Principles document?
Agree

Please share any additional comments you have on this principle:

As written, this item appears that could be interpreted that other RIRs need to provide funding, technology, and/or operational resources to support the operations of another RIR which is flagging. The RySG is unsure this was the intended meaning and suggests that when drafting the updated version of the ICP-2 document, the authors provide additional clarity.

24) Do you agree with the Handoff principle as set forth in the Proposed ICP-2 (v2) Principles document?
Strongly Agree
Please provide any other feedback you may have about the Proposed ICP-2 v2 Principles.

The Registries Stakeholder Group (RySG) represents the interests of gTLD Registry Operators. It is in the best interest of our members, and of all gTLD registries, for the Regional Internet Registries (RIRs) to operate in a stable and predictable manner and for the system that governs the RIRs to ensure such stability. We believe that the proposed principles provide a solid foundation on which to revise ICP-2 in a way that will improve the governance of the RIRs. We recognize that the principles are just an initial step, though, and that it will be critical to assess how they are put into practice in the revised version of ICP-2. The RySG looks forward to reviewing that document when the time comes.