[CRISP-TEAM] [NRO-IANAXFER] Call for submission of comment to the combined ICG proposal and the CRISP Team draft response

Izumi Okutani izumi at nic.ad.jp
Mon Aug 31 17:34:29 CEST 2015

On 2015/09/01 0:25, Andrei Robachevsky wrote:
> Good response, thank you Izumi,
> Izumi Okutani wrote on 31/08/15 17:09:
>> We have not proposed to split the IANA Functions by different operators at the time of the transition.
>>  * Since we have not proposed to splitting of the operator per function at the time of the transition,
> I suggest that we use "the numbers community" instead of "we" in these
> two instances.
> Andrei

Good point Andrei, to distinguish between "the number community" and "the CRISP Team".
The above two replacements reflected.

I have also replace "we" in later bullents points with  "the CRISP Team" for better clarity.


Dear Pranesh,

Thank you for your question about the CRISP Team comment and I note your concern about impact on the ability to chose a new IANA Numbersing Services Operator in the future.

> Could the CRISP Team please elaborate on its reasoning behind believing that a singular PTI for all three functions will not hamper its stated need to be able to sever the contract with the INSO and choose a new INSO?

The only change in the combined proposal by the ICG from the number community proposal, is PTI serving as the operator for all three IANA functions, instead of ICANN.
The number community has not proposed to split the IANA Functions by different operators at the time of the transition.

 * Since the number community has not proposed to splitting of the operator per function at the time of the transition,
   splitting the IANA Function Operator at the time of the transition will cause inconsistencies with the number community proposal. 
   - The number community proposal says:
     "considering the Internet Number Community’s strong desire for stability and a minimum of operational change, the Internet Number Community believes that ICANN should remain in the role of the IANA Numbering Services Operator for at least the initial term of the new contract"
   - Today, the IANA functions are operated by a single IANA Functions Operator (ICANN), and not by different Operators per IANA Function.
   - It is stated in the number community proposal to have priority to maintain stability and continuity in operations of the IANA Numbering Services, very minimal changes to the arrangements.
 * The CRISP Team does not observe any material changes for PTI to serve as IANA Functions Operators instead of ICANN, as we understand this as merely changes in organizational hat of the IFO, without any changes in its staff, system nor operations.
   - In terms of the conctractual arrangement, RIRs will continue to exchange the SLA with ICANN
   - Requirements for the SLA based on the number community proposal are reflected in the 2nd SLA draft.

 * The CRISP Team believes the ability to chose a new IANA Numbering Services Operator if needed in the future is ensured by description in the SLA.
   We observe the second draft SLA gives the RIRs the ability to do so by a single IFO, operated under PTI.
   - The second draft SLA addresses this point by additional clause in under Section 15.11 Sub-Contracting.  
     (See the bottom of the e-mail for the exact lanauge in the SLA). 
   - The condition to Termination remains unchanged and consistent with the number community proposal under Article 10: Term and termination.

Thanks for raising this point and I hope this clarifies your question -  Please let me know if there is any thing which remains unclear about our observation.


Service Level Agreement for the IANA Numbering Services
[Public Draft v2.0 – 5 August 2015]

"15.11.1 Operator shall not sub-contract or delegate to a third party entity for its provision
of the IANA Numbering Services under this Agreement without the prior written
consent of the RIRs, such consent not to be unreasonably withheld.

15.11.2 Notwithstanding the foregoing, any sub-contracting approved by the RIRs shall
not release Operator from, or diminish, its contractual obligations under this
Agreement and Operator shall remain fully liable to the RIRs under this

15.11.3 In the event that Operator sub-contracts or delegates the provision of the IANA
Numbering Services under Article 15.11.1 of this Agreement to a sub-contractor,
then Operator must, at the written request of the RIRs at their sole discretion,
enter into an agreement with the RIRs and sub-contractor to transfer or novate all
Operator’s rights and obligations under this Agreement to the sub-contractor."

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