[ICP2_review] Comments on RIR Governance Document

[Andrew Dul]

Comments inline

Andrew

On 4/25/25 9:36 PM, Nicholas Nugent wrote:
> Thanks for your feedback, Andrew.
>
> A few questions/comments:
>
> (1) You said, "In Section 2.3 there is no specific requirement that the applications and responses be made public." Section 2.3(a)(ii) requires the RIRs to "consider the Proposal and make a recommendation in favor of or against the Proposal and ... publish their recommendation and the reasons for their recommendation." Because the RIRs must publish their decision on any application, does that address your suggestion that the "responses be made public"?
As noted below I find just publish to be insufficient, I believe it 
should be published to everyone, not a potential subset.  One could for 
example publish a document only to Members.  While I don't think the 
authors intended it not to be public, by making it clear that it should 
be public we can avoid any future discussion about limiting access to 
the documents created and used during the implementation of the 
functions defined by this document.
>
> (2) Also, because the recommendations will be published, both the existence of the applications and various details about them will also presumably be published. Does that address your concern, or are you suggesting a requirement to publish the full text of each application (rather than as summarized by the published RIR decision)?
I see no reason not to publicly publish the full text.  We should be 
creating an open and transparent process to allow all stakeholders to 
see the process and its outcomes.
>
> (3) Can you help me understand the difference between "publish" and "publicly publish"?
I don't think of publish on its own as inherently public.  While I 
assume the authors of this draft intended publish to be a public outcome 
one could read it as publishing internally amongst the NRO or the RIRs 
or some other group.
>
> (4) Are you suggesting that any RIR's members should be able to initiate a derecognition proposal (i.e., to de-recognize another RIR)?

I'm suggesting that an RIRs could define an alternate trigger for the 
Derecognition process in their bylaws/declaration/governance_documents 
that would be different than the 25% of Members that is proposed by this 
draft.

By allowing an RIR and its members to create an alternate trigger for 
the Derecognition process (in the future as I guess no RIR governance 
documents today contemplate this function) we allow the RIRs 
individually to define an alternate trigger that may better meet the 
needs of their Members more than the 25% suggested in this draft.  Also 
some RIRs have different Member categories so it would be beneficial in 
some cases to allow a different thresholds to trigger a Derecognition.

> (5) Re: Section 4.1(g) - Yes, that appears to be a missing comma. Thanks for catching that.
>
> (6) Re: Section 4.1(l) - Our intent was that Section 4.1(l) would be broader than handoff following de-recognition. Yes, establishing continuity procedures in advance will facilitate a complete handoff if an RIR is derecognized (Section 5.3). But there could also be situations where an RIR might experience a hardship for which it might be necessary for another entity to only *temporarily* take over providing services. That's why the section doesn't reference the handoff procedures in Section 5.3. Please let me know if you still have concerns.

I think I understood the intent to be able to do the Handoff via this 
method, but the text used in 4.1.l was different than the text in the 
5.3.a Handoff "successor or interim entity" so I thought it might be 
beneficial to note that one of the purposes of the Continuity 
requirement was to facilitate a Handoff if necessary.


>
> Thanks,
>
> Nick
>
> -----Original Message-----
> From: ICP2_review <icp2_review-bounces at arin.net> On Behalf Of Andrew Dul via ICP2_review
> Sent: Friday, April 25, 2025 8:03 PM
> To: icp2_review at arin.net
> Subject: [ICP2_review] Comments on RIR Governance Document
>
> Hello,
>
> Below please find my comments regarding the recently published
> Apr-14-2025 draft of the "RIR Governance Document"
>
>
> In Section 2.3 there is no specific requirement that the applications
> and responses be made public.  I recommend inserting language to make
> this clear.
>
> 2.3.a.i Add "A Candidate RIR's Proposal shall be publicly published."
>
> 2.3.a.ii Modify to "shall publicly publish"
>
> 2.3.a.iv Modify to "shall publicly publish"
>
> Regarding Nonrecognition Proposals
>
> I would suggest adding language that allows an RIR in its bylaw or other
> governance documents which defines specific criteria for initiating a
> Derecognition proposal
>
> For example add a
>
> 2.3.b.i.c A Derecognition action of an RIRs Members as defined in an
> RIR's governance documents.
>
> Regarding Recognition Criteria
>
> 3.1.b uses the undefined criteria "broadly support" I would suggest
> considering more specific criteria either by referring to other more
> specific definitions or creating a definition that would support the intent.
>
> 3.1.c uses the phrase "committed to supporting" again this criteria is
> not clearly defined.
>
> Regarding Ongoing Commitments
>
> While I understand the desire to not burden the document with lots of
> text regarding detailed commitments, I suggest that some of the
> requirements could benefit from some additional details, specifics, or
> references to other standards.
>
> For example
>
> 4.1.d - "good corporate governance" is an undefined term which could
> benefit from specific criteria which defines good governance or pointing
> to an governance standard or auditing standards or allow the NRO to
> define later and use the phrasing used in 4.1.k "using standard
> protocols and specifications as adopted by the NRO"
>
> 4.1.g - Is there a missing comma between "impartial publicly" , is the
> hyphen in "Community-driven" intentional how is this different from a
> space as a separator?    e.g. should this be "open, transparent,
> impartial, publicly documented and Numbering Community driven"
>
> 4.1.j - Modify to "publicly publish"
>
> 4.1.l - Should this include reference to 5.3.a Handoff successor -
> Modify to "... to enable another RIR, entity designated by the other
> RIRs, or Handoff successor to perform..."
>
>
>
> Thanks for your consideration of these comments.
>
> Andrew
>
>
>