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: Benedetta Rossi
Date: 6 Dec 2024
Affiliation: African GAC Members
1) Do you agree with the Authority principle as set forth in the Proposed ICP-2 (v2) Principles document?
Agree

Please share any additional comments you have on this principle:

Any decision by ICANN related to its final authority to recognize a Candidate RIR or to derecognize an RIR, should not be taken without consulting with GAC members of the relevant region, whether during a meeting or intersessionally through a well-defined process.

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:

ICP-2 may be amended based on an agreement between ICANN and all RIRs. This reflects a collaborative approach to the evolution of Internet resource management policies. To ensure transparency and fairness, it is crucial that changes be adopted through an open consultation process with well-defined criteria, allowing the participation of all the community.

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

Please share any additional comments you have on this principle:

This provision ensures a smooth and fair transition for RIRs (Regional Internet Registries) facing conflicts between the proposed amendment and their internal policies. It provides a reasonable grace period for adjusting practices, allowing RIRs to comply without disrupting ongoing operations. This compliance process supports stability in Internet governance while enabling a gradual adaptation to new requirements. The specific nature of the grace period enhances predictability and transparency of expectations. Lastly, it protects RIRs from immediate penalties, offering them a period of adjustment in line with principles of sound management and flexibility.

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

Please share any additional comments you have on this principle:

In that context it is important to set up escrow services, preferably in the region, to cater for any service interruption that may arise, thus ensuring continuity of operations and minimizing the impact on users and stakeholders. This approach provides a safeguard by securing critical data and services, allowing for a swift recovery and reducing the risks associated with potential disruptions.

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:

This promotes clear and well-defined boundaries for each RIR’s responsibility, ensuring that the management of IP address resources is organized and efficient across large multinational regions. By avoiding overlap between RIRs, it reduces potential conflicts and confusion, thereby fostering a smoother and more transparent allocation process.

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:

A Candidate RIR must meet or demonstrate that it can meet all the requirements of an RIR specified in ICP-2 and commit to continue to comply with future revisions, to be recognized as an RIR.

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

Please share any additional comments you have on this principle:

An RIR, once recognized, must continually meet all the requirements specified in ICP-2, and any future revisions thereof, in an auditable fashion.

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

Please share any additional comments you have on this principle:

An RIR that does not continue to meet all the requirements specified in ICP-2, or any future revisions thereof, and fails to rectify its status within a reasonable specific grace period, will be derecognized as an RIR. In that context it is important to set up escrow services, preferably in the region, to cater for any service interruption that may arise, thus ensuring continuity of operations and minimizing the impact on users and stakeholders. This approach provides a safeguard by securing critical data and services, allowing for a swift recovery and reducing the risks associated with potential disruptions.

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

Please share any additional comments you have on this principle:

In addition to the support of Resource Holders in the Region, Governments of the region must also broadly provide support, since they are the stakeholder that represents the public interest, especially of communities that are not yet online. In that respect, ICANN’s Governmental Advisory Committee (GAC) serves as potential venue to seek such support. Concerns/support by the community of that region (if expressed) should be also taken into consideration before granting recognition

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

Please share any additional comments you have on this principle:

There is need to define the community in the context of the RIRs. For example: Resource Holders, Governments, Service Providers, End-Users, … The Candidate RIR must also demonstrate that its community is willing to use the Candidate RIR’s IP resource allocation services once recognized.

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:

Financial stability allows the RIR to maintain the necessary infrastructure, staff, and resources to provide reliable services to the region it serves. Independence ensures that the RIR can make decisions based solely on the needs of its community, free from monopolized or external influence. Together, these principles help build trust and confidence among stakeholders, contributing to the long-term success and integrity of the RIR's operations.

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:

Operating on a not-for-profit basis, is a crucial principle that needs to be incorporated in the establishment process of an RIR per the applicable jurisdiction(s).

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

Please share any additional comments you have on this principle:

An RIR must follow corporate governance procedures consistent with best practices in its jurisdiction(s). This ensures that the RIR operates with transparency, accountability, and ethical standards, aligning with legal and regulatory frameworks in its jurisdiction(s). Adhering to best corporate governance practices fosters trust and supports the RIR's long-term credibility and effectiveness.

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

Please share any additional comments you have on this principle:

The definition of Members vs. Resource Holders needs to be clear and agreed upon by the relevant RIR community. To the extent possible a Candidate RIR should follow best practice in other established RIRs for its governance structure.

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

Please share any additional comments you have on this principle:

There is need to define the community in the context of the RIRs. For example: Resource Holders, Governments, Service Providers, End-Users, … An RIR must maintain a community-driven policy development process that is open, transparent, accountable, neutral, and publicly documented.

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

Please share any additional comments you have on this principle:

An RIR must operate and apply its policies in a manner that is neutral, consistent and predictable.

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

Please share any additional comments you have on this principle:

This ensures transparency and accountability, allowing stakeholders to assess the RIR's operations and decision-making processes.

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:

An RIR must participate in regular audits by an external and independent auditor to ensure that it is continuing to comply with ICP-2 and any agreed future updates.

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:

An RIR must provide stable, reliable, secure, accurate, and accountable allocation, registration, and directory services, as well as related technical services, in a timely fashion, using standard protocols and specifications for cross-RIR compatibility.

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

Please share any additional comments you have on this principle:

In that context it is important to set up escrow services, preferably in the region, to cater for any service interruption that may arise, thus ensuring continuity of operations and minimizing the impact on users and stakeholders. This approach provides a safeguard by securing critical data and services, allowing for a swift recovery and reducing the risks associated with potential disruptions.

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:

There is need to clearly define “being captured” in the ICP-2 draft.

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

Please share any additional comments you have on this principle:

Resiliency, stability and continuity of the global Internet number registry system are crucial principles that need to be maintained at all times.

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

Please share any additional comments you have on this principle:

In that respect ICANN may seek the support of the respective regional community. ICANN and especially its GAC constituency, as well as all other RIRs must provide all feasible support, if requested, to assist an RIR to cure any failure to comply with ICP-2 before derecognizing the RIR. Relevant regional GAC community can play a crucial role in that respect.

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

Please share any additional comments you have on this principle:

This requirement ensures a seamless transition in the event of derecognition, promoting continuity and minimizing disruption to the global Internet resource management system. By cooperating with ICANN and other RIRs, the derecognized RIR helps safeguard the stability of services and ensures that its responsibilities are effectively transferred to a designated successor or interim entity.

Please provide any other feedback you may have about the Proposed ICP-2 v2 Principles.

Re-iterate the concern that Africa is not represented on the ASO AC, while this critical review process is taking place, and re-emphasize the urgency for the three vacant African seats to be filled by the African community