[ICP2_review] Comments on the RIR Governance Document

[Lee Howard]

First, I want to thank the NRO NC for the clear and considerable work 
they have put into this document. Although I recall extensive work on 
ICP-2, I think this has exceeded the initial work by an order of magnitude.

I also want to thank the ARIN region members of the NRO NC for their 
webinar today on the new document. Nick in particular did a great job of 
providing much of the context for why the document reads as it does. 
Great job, and thank you.

In reaction to that webinar, I have taken some time to read the document 
closely. My notes are below, but for reference I also pasted it into a 
Google Doc where my edits and comments may be clearer in context: 
https://docs.google.com/document/d/1Sw1U1o4W7-ZkzsZOHvzYpJycsqQhRbRSgjzkryXU8P4/edit?usp=sharing 
<https://docs.google.com/document/d/1Sw1U1o4W7-ZkzsZOHvzYpJycsqQhRbRSgjzkryXU8P4/edit?usp=sharing>


ORGANIZATION

Broadly, I think the organization makes sense. There are a few places 
that I thought were confusing:

1. Use of outline format 1.1(a)(i)(A) made it really difficult to keep 
track of where I was. It's easier to see the hierarchy with 1.1.1.1.1, 
and I wouldn't be surprised if that's an accessibility guideline.

2. There are several items in 2.3 that are more fully discussed in later 
sections. At the least, cross-reference Regonition and Derecognition 
with their respective sections. To illustrate what I mean, here's a 
partial outline, showing the same headings repeated:

    Preamble
    Article 1: Definitions, Interpretation, and Implementation
    Article 2: Internet Numbers Registry System
    . . .
    2.3. Change to RIR Status.
    (a) Recognition
    (b) Dercognition
    (c) ICANN Decision
    2.4. Ad Hoc Audit.
    . . .
    Article 3: Recognition
    Article 4: Ongoing Commitments
    . . .
    4.2 Audit
    . . .
    Article 5: Emergency Continuity
    Article 6: Derecognition
    Article 7: Amendment



DEFINITIONS

Generally, I think terms that only appear once do not need to be in the 
Definitions section; they are better defined /in situ,/ where the 
context is provided.

Affiliate only appears once, 4.1(o), as part of Control, and only as a 
participle. Just roll it into the definition of Control.

The ASO MoU doesn't need to be defined up front; spell it out the one 
time it's mentioned, in the definition of Global Policy.

The definition of Control refers to control of an entity participating 
in RIR governance. Every use of the term Control in the document refers 
to control of the RIR.

Global Policy only appears once.

Internet Numbers Registry System has a definition, but also all of 
Article 2 describing it. Maybe don't define it early.

Resource Holder specifies "registered with an RIR" which excludes the 
few remaining organizations with delegations directly from IANA.

RIR Services is very traditional; is support for RPKI an RIR Service? It 
should be, since it has profound operational implications. Maintenance 
of IPv6.ARPA and IN-ADDR.ARPA should also explicitly in scope.

In several cases, it is unclear whether RIR or ICANN refer to the staff, 
executive, Governing Body, or communities. In some  cases (audits, 
emergency continuity), it might even refer to a contracted third party.  
It should be explicit--where I think the community may be deciding 
something, another person might think the CEO or Board speaks for the 
community.


TERMS

2.3(a)(i) says a Proposal for Recognition must be submitted, but doesn't 
say what needs to be in it. Hours later, I read section 3.1. Suggest: 
*by submitting a Proposal for Recognition, as specified in 3.1, in writing *

It is unclear how a Candidate RIR and incumbent RIR would negotiate for 
territory. It's mentioned in 3.1(a), but I would think a Candidate RIR 
should have support from the affected RIR before event submitting a 
Proposal.

2.3(a)(v)(C) references 2.3(a)(iii), which is for Approval, but also 
needs to include the following subsection on Rejection.

2.4 "Compliance with this document" is pretty good. But is the audit 
conducted by ICANN staff, or consultants, and/or in conjunction with the 
other RIRs? What happens to the audit? Does it go to the ICANN Board, 
the subject RIR, the full NRO, is it published? Is the subject RIR 
expected to respond? Remediate? Appeal? It's weird to have the so far 
separated from 4.2. Aren't they the same? At the very least, 
cross-reference them.

2.8 "reasonable timeframes" sounds good, but I just want to point out 
that getting at least one meeting cycle out of every Board and Numbering 
Community plus ICANN almost certainly requires at least two years. 
That's after years of building regional support for a new RIR, or after 
an RIR is in failure.

3.1(f) I would like to strike "relative to the then-existing state of 
affairs." It is conceivable that we can see an event happening 2-3 years 
from now, and take action to improve the system in preparation for that 
event. If the improvement can only be to current state, then we have to 
wait for things to get worse before we can make them better.

4.1(g) I would like to add "periodically" before "elected." Governing 
Body members may not be elected for life.

5.1(a) "*An Emergency Continuity may only be initiated" *by whom? If a 
natural disaster affects the RIR HQ and surrounding area, who is 
authorized to declare an Emergency Continuity (event)?

5.1(c) "must cooperate" to the extent reasonably possible. In the case 
of major natural disaster, there may not be anybody who can cooperate.

5.1(d) "*unless renewed pursuant to the conditions" is unclear; there 
are no renewal provisions. I *propose: "But may be continued by 
repeating the steps to initiate an Emergency Continuity"

6.2 I propose to strike "if requested." Several failure modes may leave 
an RIR without someone to make the request.

6.2 "*outweigh the benefits of continuing to tolerate"I would like to 
add "or mitigate." It's more consistent with derecognition being a last 
resort, and giving the RIR a chance to fix things.*

**

WORD CHOICES AND TYPOGRAPHICAL

Preamble paragraph 3 has a stray space before the first line.

Change

*This Governance Document for the Recognition, Operation, and 
Derecognition of Regional Internet Registries (the “RIR Governance 
Document”) succeeds the document Internet Coordination Policy‑2...*

*to*

*This Governance Document for the Recognition, Operation, and 
Derecognition of Regional Internet Registries (the “RIR Governance 
Document”) supersedes the document Internet Coordination Policy‑2...*

*"Succeeds" means "comes after." We intend to replace ICP-2.*

2.3(v)(A) replace "outline" with "describe." We need the details, here.

2.3(c)(i) change decision to Notice of Decision. Notice of Decision is a 
defined term, and should be explicitly used here to require ICANN to 
publish the formal Notice, not just yea or nay.

4.1(n) replace "community" with "Numbering Community" to make explicit 
that the RIRs must convene multistakeholder meetings, not just Number 
Resource Holders or Members.

5.1 Replace

     "*If an RIR is unable to adequately provide all or any part of its 
RIR Services to its Service Region,"*

with

*"If an RIR is unable to adequately provide all or any part of its RIR 
Services for its Service Region,"*

*I can imagine failure modes where people inside the region can do WHOIS 
lookups, validate ROAs, and search ipv6.arpa, but where people outside 
the region can't reach those services. However, the RIRs have a 
responsibility to the global community, not just their region. *

*Footnote 1, typo in "accessible." Also, please lit the URL rather than 
buying it under "here"*.**

****

Again, thank you to the entire NRO NC for all of the work you have put 
into this. Although my notes here look lengthy, I think you'll see that 
in almost every case, I agree with what you have done, and propose only 
minor clarifications.

I look forward to seeing the document ratified!

Sincerely,

Lee Howard

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