[ARIN-consult] PDP Consultation Reminder
owen at delong.com
Wed Jun 27 22:07:37 EDT 2012
On Jun 27, 2012, at 5:34 PM, David Farmer wrote:
> On 6/26/12 20:03 CDT, William Herrin wrote:
>> A quick caveat: these comments are intended to be constructive,
>> suggesting improvement. If any seems otherwise, then I did not explain
>> myself well and you misunderstood me.
>>> One. 3.1. Policies, not Processes, Fees, or Services
>>> Changes to policy that are purely editorial in nature
>>> are beyond the scope of the Policy Development
>>> Process and may only be made with the concurrence
>>> both the ARIN Advisory Council and ARIN Board of
>>> Trustees regarding their non-substantial nature.
>> This is a dangerous sentence. I foresee bitter arguments over whether
>> or not a change was substantive. Even if "concurrence" is intended to
>> mean "unanimous consent" of the board and council (in which case it
>> should probably say so), this statement facilitates edits to the PDP
>> without any process for prior public review, directly contradicting
>> the objective of One 5.2 (Open & Transparent Processes). And for
>> certain if you can't get unanimous consent of the board and council
>> that a change is "purely editorial" then it isn't.
> I'm glad PDP was a typo, and you meant NRPM.
> So, I'm not hearing you say we don't need or want an editorial change process for the NRPM that is simpler than the full the PDP. But I think I hear you saying that we need public notice of what the proposed changes are sometime before they are made. If there is any real debate then it probably isn't an editorial change. But without notice, people can only object after the fact, which then crates a big problem.
> I think what was ARIN-prop-169 is an excellent example. We shouldn't necessarily need a proposal to initiate the process. However, by having this one initiated by a proposal there was public notice and an opportunity for people to raise any objections which there were none. So, I think public notice needs to be added as this part of the process.
> I don't think this level of detail needs to be in the PDP, but I think the procedure should look something like this for a successful editorial change;
> 1. Staff formally prepares proposed editorial change
> 2. AC provides concurrence to proposed editorial change
> 3. Public Notice is provided of proposed editorial change
> 4. Board provides concurrence to proposed editorial change
> 5. Staff incorporates editorial change in the next revision of NRPM
I like this, but I'd like to propose that we reverse steps 2 and 3.
If we want to provide public notice, I would prefer that the AC be allowed to consider any response to that public notice in their decision.
> I would propose the following change to the third paragraph of section 3.1 of the proposed PDP, adding "public notice and";
> Changes to policy that are purely editorial in nature are beyond the scope of the Policy Development Process and may only be made with public notice and the concurrence both the ARIN Advisory Council and ARIN Board of Trustees regarding their non-substantial nature.
> I think this restores the necessary openness and transparency to the process, and the procedural details don't need to be in the PDP.
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