Google thanks the volunteers that worked on the revised draft of the Internet Coordination Policy - 2. It is a good first step towards more mature Regional Internet Registries (RIRs) governance.

We fully support issuance of a governance that provides clarity to the obligations of RIRs and adds a mechanism for auditing whether those obligations are being met. Further, the addition of guidelines for the derecognition of non-compliant RIRs adds accountability and predictability in RIR governance and enhances the overall stability of the DNS. 

With that in mind, we encourage the drafters to consider adding further specificity with regards to the following: 

Clearer delineation of whose policies are in effect if derecognition of an RIR is proposed;

Potential timelines on the derecognition process; and

Discussion of technical implications following a derecognition, e.g. should there be a requirement for data to be escrowed in a canonical manner.

Perhaps a table-top exercise to run through the proposed derecognition process could help uncover potential gaps in the documentation.