[CRISP-TEAM] Responses to GAO questions

Izumi Okutani izumi at nic.ad.jp
Fri May 15 17:40:27 CEST 2015


Janvier,

> As you quoted some main documents, may be do  list them in reference:
> -SLA
> -Number resources proposal
> - Request for Proposal  on a rebidding process (NTIA)

Good point, I agree. 

Please see below the latest reponse to the GAO.

For Q1:

 - URLs of each RIRs's PDP added (suggested by Mwendwa)
 - Added description that there are two types of policies: global and regional, RIRs distibute based on regional policies 
 - Addded description about ASO AC about its compositiona and that it doesn't develop/make policy decisions

For Q2:

 - References suggested by Janvier added

Bill, my  current understsanding of the intention of your post was to help summarize the issues and stimulte discussions within the CRISP Team but not necessary expecting text changes.

>From my reading, what you have described in 1) and 2) is consistent with what is described here.
3) is  additional point in relation to implementation and 4) is not directly related to the point being asked, which is another issue on seperation on the three IANA functions, which are not direct answers to the question.


If I misunderstood and  you are expecting some changes in our response, please share your suggestions for the text changes on the ML. 

----
1.    What is the role of the Address Supporting Organization (ASO) in the policy development process for the numbers community? What, if any, role do the other ICANN supporting organizations or ICANN advisory committees play any role in policy development for the numbering community

Internet Number Resource Policy development does not take place within the ICANN community, but within the five separate regions of the RIRs, in a bottom-up, open and inclusive manner. 
Further, there are two types of policies: global and regional.

Each RIR community develops its own "regional number resource policies" according to their established bottom-up policy development processes, based on the needs within that community. These processes are well established and documented, and are open to any interested party or stakeholder group, without restriction. Distribution of the resources from the RIRs to its account holders are based on the respective regional policies of the RIR.  

 AFRINIC: http://www.afrinic.net/en/community/policy-development <http://www.afrinic.net/en/community/policy-development>
 ARIN: https://www.arin.net/policy/pdp.html <https://www.arin.net/policy/pdp.html>
 APNIC: https://www.apnic.net/community/policy <https://www.apnic.net/community/policy>
 LACNIC: http://www.lacnic.net/web/lacnic/proceso-de-desarrollo-de-politicas <http://www.lacnic.net/web/lacnic/proceso-de-desarrollo-de-politicas>
 RIPE: https://www.ripe.net/participate/policies <https://www.ripe.net/participate/policies>

There is also a limited set of policies that apply to the allocation of Internet resources by IANA to the RIRs, called "global policies". There are currently three global policies, for the allocation of IPv4 addresses, IPv6 addresses and AS numbers respectively, from IANA to the RIRs. These policies act as the framework for the relatively simple and administrative task of allocating blocks of such number resources to the RIRs by IANA.

The global policies are also developed in a bottom-up manner, through each regional RIR community, with each RIR community ratifying the proposed global policy. The role of the ASO Address Council (ASO AC), is to receive the coordinated proposal, review the process by which the proposal was developed and ratified and, under the terms of the ASO Memorandum of Understanding, and pass it to the ICANN Board of Directors for ratification as a global policy. According to its bylaws, ASO should be“formed through community consensus" and composed of three representatives from each of the five RIR region, with fifteen members in total. The ASO does not develop, approve, or implement regional or global Internet number resource policies. See <https://www.nro.net/policies> for more details.


REFERENCES
ASO Memorandum of Understanding
https://aso.icann.org/documents/memorandums-of-understanding/memorandum-of-understanding/

Internet resource global policies
https://www.nro.net/policies/global-policies-development-process


2. In its transition proposal the numbers community has proposed that a new contract be established between the IANA Numbering Services Operator and the five RIRs. This arrangement would allow the RIRs to cancel and rebid the contract if needed, for example, to find a new IANA Numbering Services Operator. If such a circumstance were to arise, how easy or difficult would this be in practice and to what extent might this create any disruptions?


As stated in our proposal, there are no concrete needs or plans to change its operator at this point. The Internet Numbers community is proposing the ability for the RIRs to choose the IANA Numbering Services operator as a possibility if needed. The arrangement to terminate and rebid the contract if needed already exists in the contract between the NTIA and ICANN as the IANA Functions Operator. 

The SLA provides the RIRs with the option to terminate the SLA during its term if the Operator failures to perform and, after going through arbitration, fails to remedy such failure to perform, or not to renew the SLA at the end of its term.

With regards to termination, we note that the NTIA contract provides the US government with the same reasons for termination (page 2 of the NTIA contract and sections E.2.g.1.ii and I.67.i of the NTIA contract). Additionally the NTIA contract gives the option to the US government to terminate the NTIA contract for more reasons (sections I.51 and I.52 of the NTIA contract). 

Based on the above, we believe that the SLA provides fewer reasons for the termination of the SLA than the NTIA contract and thus it would not be easier to terminate and rebid the SLA.

With regards to rebidding for the contract, the NTIA has a rebidding process today called "Request for Proposal", which allows proposals from anyone interested in serving as the IANA Functions Operator, not limiting candidates of the bidding to the existing IANA Functions Operator (as an example of this process we refer to the last re-issue of the Request for Proposal (RFP) made on April 16, 2012, published on the NTIA website).

Further, the numbers community have listed "Continuity of Operations" in the numbers proposal, as a principle to be reflected in the SLA, "If, at the end of the term, the RIRs decide to sign an agreement for provision of IANA Numbering Services by a different party, the previous IANA Numbering Services Operator will be obliged to ensure an orderly transition of the function while maintaining continuity and security of operations."

As stated in the number resources proposal, the Internet Number Community has expressed its strong desire for stability of the IANA Numbering Services. RIRs, as the direct customers of the IANA Numbering Services, will be more strongly affected than NTIA, if any disruptions are created as a result of a cancelation or rebidding of the contract. It is in the interests of the RIRs to ensure continued stability of the IANA Numbering Services in a possible event of changing the IANA Numbering Services operator.


REFERENCES 
The proposal from the numbers community: Response to the IANA Stewardship Transition Coordination Group Request for Proposals on the IANA from the Internet Number Community
https://www.nro.net/wp-content/uploads/ICG-RFP-Number-Resource-Proposal.pdf

First version of the SLA draft: Call for Comments for a Draft SLA for the IANA Numbering Services
https://www.nro.net/news/call-for-comments-for-a-draft-sla-for-the-iana-numbering-services

IANA Functions Contract: With RFP published
http://www.ntia.doc.gov/page/iana-functions-purchase-order

----
On 2015/05/15 6:28, Janvier Noulaye wrote:
> @Izumi
> As you quoted some main documents, may be do  list them in reference:
> -SLA
> -Number resources proposal
> - Request for Proposal  on a rebidding process (NTIA)
> 
> Warm regards,
> /Janvier Ngnoulaye
> 
> 2015-05-14 16:22 GMT+01:00 Izumi Okutani <izumi at nic.ad.jp>:
> 
>> CRISP Team,
>>
>>
>> This is a draft response to the second additional question.
>> As Nurani has stated, I welcome comments by Friday 15, 12.00 UTC.
>>
>> After incorporating any feedback you may have, we will then send our
>> response to the GAO.
>>
>> As had been suggested earlier on the CRISP Team ML through Nurani, we
>> would like to share the response we submit to the GAO on the
>> ianaxfer at nro.net ML.
>>
>> ----
>> 2.    In its transition proposal the numbers community has proposed that a
>> new contract be established between the IANA Numbering Services Operator
>> and the five RIRs. This arrangement would allow the RIRs to cancel and
>> rebid the contract if needed, for example, to find a new IANA Numbering
>> Services Operator. If such a circumstance were to arise, how easy or
>> difficult would this be in practice and to what extent might this create
>> any disruptions?
>>
>> [Draft response]
>>
>> As stated in our proposal, there are no concrete needs or plans to change
>> its operator at this point. The Internet Numbers community is proposing the
>> ability for the RIRs to choose the IANA Numbering Services operator as a
>> possibility if needed. The arrangement to terminate and rebid the contract
>> if needed already exists in the contract between the NTIA and ICANN as the
>> IANA Functions Operator.
>>
>> The SLA provides the RIRs with the option to terminate the SLA during its
>> term if the Operator failures to perform and, after going through
>> arbitration, fails to remedy such failure to perform, or not to renew the
>> SLA at the end of its term.
>>
>> With regards to termination, we note that the NTIA contract provides the
>> US government with the same reasons for termination (page 2 of the NTIA
>> contract and sections E.2.g.1.ii and I.67.i of the NTIA contract).
>> Additionally the NTIA contract gives the option to the US government to
>> terminate the NTIA contract for more reasons (sections I.51 and I.52 of the
>> NTIA contract).
>>
>> Based on the above, we believe that the SLA provides fewer reasons for the
>> termination of the SLA than the NTIA contract and thus it would not be
>> easier to terminate and rebid the SLA.
>>
>> With regards to rebidding for the contract, the NTIA has a rebidding
>> process today called "Request for Proposal", which allows proposals from
>> anyone interested in serving as the IANA Functions Operator, not limiting
>> candidates of the bidding to the existing IANA Functions Operator (as an
>> example of this process we refer to the last re-issue of the Request for
>> Proposal (RFP) made on April 16, 2012, published on the NTIA website).
>>
>> Further, the numbers community have listed "Continuity of Operations" in
>> the numbers proposal, as a principle to be reflected in the SLA, "If, at
>> the end of the term, the RIRs decide to sign an agreement for provision of
>> IANA Numbering Services by a different party, the previous IANA Numbering
>> Services Operator will be obliged to ensure an orderly transition of the
>> function while maintaining continuity and security of operations."
>>
>> As stated in the number resources proposal, the Internet Number Community
>> has expressed its strong desire for stability of the IANA Numbering
>> Services. RIRs, as the direct customers of the IANA Numbering Services,
>> will be more strongly affected than NTIA, if any disruptions are created as
>> a result of a cancelation or rebidding of the contract. It is in the
>> interests of the RIRs to ensure continued stability of the IANA Numbering
>> Services in a possible event of changing the IANA Numbering Services
>> operator.
>> ----
>>
>> Izumi
>>
>> On 2015/05/14 20:51, Nurani Nimpuno wrote:
>>> Dear all,
>>>
>>> As explained by Izumi, the GAO had two additional questions that they
>> sent to us after our meeting:
>>>
>>>       1.      What is the role of the Address Supporting Organization
>> (ASO)
>>>       in the policy development process for the numbers community?
>>>       What, if any, role do the other ICANN supporting organizations or
>>>       ICANN advisory committees play any role in policy development for
>>>       the numbering community?
>>>
>>>       2.      In its transition proposal the numbers community has
>> proposed
>>>       that a new contract be established between the IANA Numbering
>> Services
>>>       Operator and the five RIRs. This arrangement would allow the RIRs
>> to
>>>       cancel and rebid the contract if needed, for example, to find a new
>>>       IANA Numbering Services Operator. If such a circumstance were to
>> arise,
>>>       how easy or difficult would this be in practice and to what extent
>> might
>>>       this create any disruptions?
>>>
>>> I have drafted a response to the first question below. Izumi will
>> circulate her draft on the second question shortly.
>>>
>>> ~~~~~~~
>>>> 1.    What is the role of the Address Supporting Organization (ASO) in
>> the policy development process for the numbers community? What, if any,
>> role do the other ICANN supporting organizations or ICANN advisory
>> committees play any role in policy development for the numbering community?
>>>
>>> Internet Number Resource Policy development does not take place within
>> the ICANN community, but within the five separate regions of the RIRs, in a
>> bottom-up, open and inclusive manner.
>>>
>>> Each RIR community develops its own "regional number resource policies"
>> according to their established bottom-up policy development processes,
>> based on the needs within that community. These processes are well
>> established and documented, and are open to any interested party or
>> stakeholder group, without restriction.
>>>
>>> There is also a limited set of policies that apply to the allocation of
>> Internet resources by IANA to the RIRs, called "global policies". There are
>> currently three global policies, for the allocation of IPv4 addresses, IPv6
>> addresses and AS numbers respectively, from IANA to the RIRs. These
>> policies act as the framework for the relatively simple and administrative
>> task of allocating blocks of such number resources to the RIRs by IANA.
>>>
>>> The global policies are also developed in a bottom-up manner, through
>> each regional RIR community, with each RIR community ratifying the proposed
>> global policy. The role of the ASO Address Council (ASO AC), is to receive
>> the coordinated proposal, review the process by which the proposal was
>> developed and ratified and, under the terms of the ASO Memorandum of
>> Understanding, and pass it to the ICANN Board of Directors for ratification
>> as a global policy.
>>>
>>> REFERENCES
>>> ASO Memorandum of Understanding
>>>
>> https://aso.icann.org/documents/memorandums-of-understanding/memorandum-of-understanding/
>>>
>>> Internet resource global policies
>>> https://www.nro.net/policies/global-policies-development-process
>>> ~~~~~~~
>>>
>>> We hope to submit our responses at the end of this week. Therefore, can
>> I please ask you to provide your comments on this before Friday 15, 12.00
>> UTC.
>>>
>>> Kind regards,
>>>
>>> Nurani
>>>
>>>
>>>
>>>
>>>> On 23 apr 2015, at 20:23, Izumi Okutani <izumi at nic.ad.jp> wrote:
>>>>
>>>> Hi all,
>>>>
>>>>
>>>> The meeting with GAO went well I think.
>>>>
>>>> As highlights, below are the facts which were not initially recognized
>> by GAO and helped that we shared:
>>>>
>>>> RIR Forum
>>>> - They weren't aware that RIRs are not just the registries but also
>> facilitating an open, inclusive bottom-up community
>>>>   Therefore, transitionining the stewardship of IANA Numbering Services
>> to RIRs mean that this numbering community in RIR forums, which anyone can
>> participate would be able to have their voices
>>>>
>>>> PDP for Numbers are outside the ICANN
>>>> - ICANN forum and its community for policy development is focused on
>> names. Bottom up policy development for the Number Resources Community
>> takes place outside the ICANN, in the RIR forums.
>>>>   While the ICANN Board approves the global policies, this is at the
>> very last point of the PDP for the numbers and elements of their decision
>> making is minimal, such as ensuring the process was followed.
>>>>   ASO as the representatives of the each RIR regions provide advice to
>> ICANN Board in approval of the global policies.
>>>>   It should also be noted that global policies are limited only for
>> distribution from IANA to RIRs, and most pollicies are developed under each
>> RIR forums, independently, for distribution by RIRs to its respective
>> stakeholders
>>>>
>>>> There was also a question related to ensuring accountability of the
>> IANA Numbering Services through the SLA - wouldn't the ability to terminate
>> the SLA lead to splitting of the IANA functions?
>>>> Are there other ways to address accountability before going to this
>> option?
>>>>  - I explained that the idea is to have the community have this
>> possibility if we wish
>>>>  - There are clauses in the SLA which ensures the serive level be met
>> with specific points listed
>>>>  - ICANN has been providing the IANA Numbering Services to the RIRs for
>> over 20 years and the service level as been satisfactory
>>>>
>>>>
>>>> Other questions are based on what Nurani has shared on the CRISP Team
>> ML as the final version, with our reponses basically in line with what we
>> had written out (they were not submitted to GAO but as a reference for our
>> verbal reponses).
>>>>
>>>> As the next steps:
>>>> We are planning to submit a written reponse to GAO to share accurate
>> information for the questions. We will share with the CRISP Team before
>> submission.
>>>>
>>>> Nurani and I discussed that it would be helpful to share the complete
>> response from us with the global ianaxfer list as well, and possibily
>> publish it.
>>>> I think this would be good not just for transparency but anyone who are
>> not familiar with our community would be able to understand better about
>> the number resources community's involvement with IANA and our observations
>> on the stewardship transition.
>>>>
>>>> Would be interested to hear your feedback, especially if you have other
>> thoughts on this.
>>>>
>>>>
>>>> Thanks,
>>>> Izumi
>>>>
>>>>
>>>> On 2015/04/23 20:07, Nurani Nimpuno wrote:
>>>>> Hi all,
>>>>>
>>>>> In preparation of our conference call with the GAO today, Izumi and I
>> further polished the answers to the questions provided by the GAO.
>>>>>
>>>>> Please find attached the final text.
>>>>> As we will have a conference call to discuss the questions, the
>> document is merely a guide for our discussion.
>>>>>
>>>>> Kind regards,
>>>>> Nurani
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>> On 21 apr 2015, at 10:23, Izumi Okutani <izumi at nic.ad.jp> wrote:
>>>>>>
>>>>>> Many thanks Nurani and thank you to ARIN and RIPE NCC for helping us
>> draft the response.
>>>>>> Attached are my suggested edits.
>>>>>>
>>>>>> As a general observation, there was nothing in the responses which I
>> diagree but I felt some responses would work better if they were placed in
>> other parts and wasn't sure if we responded to all questions.
>>>>>> I therefore moved some of the responses and I added some additional
>> response to the parts which seemed to me that we haven't responded to the
>> questions.
>>>>>>
>>>>>>
>>>>>> CRISP Team,
>>>>>> I am happy to clarify on anything which is not clear in my edits/your
>> feedback is welcome especially on possible concerns.
>>>>>>
>>>>>>
>>>>>> Izumi
>>>>>>
>>>>>> On 2015/04/20 18:03, Nurani Nimpuno wrote:
>>>>>>> Hi all,
>>>>>>>
>>>>>>> Please find attached draft text responding to the questions sent to
>> us by the GAO.
>>>>>>>
>>>>>>> We have used a lot of the text that ARIN put out (thank you ARIN!)
>> and the RIPE NCC offered to draft this text (thank you RIPE NCC!).
>>>>>>>
>>>>>>> Izumi and I have the call with the GAO on Thursday UTC 13.00 to
>> provide the number community's response to their questions.
>>>>>>>
>>>>>>> We would welcome any comments, additions or corrections to the text
>> that you have. Please provide your input to the list by tomorrow, Tue 21st
>> at 13.00 UTC.
>>>>>>>
>>>>>>> Kind regards,
>>>>>>>
>>>>>>>
>>>>>>> Nurani
>>>>>>>
>>>>>>>
>>>>>>>
>>>>>>> _______________________________________________
>>>>>>> CRISP mailing list
>>>>>>> CRISP at nro.net
>>>>>>> https://www.nro.net/mailman/listinfo/crisp
>>>>>>>
>>>>>>
>>>>>> <Clean_GAO Engagement on the Internet Domain Name System Discussion
>> Guide_EDIT_IO20150421.docx><Redline_GAO Engagement on the Internet Domain
>> Name System Discussion
>> Guide_EDIT_IO20150421.docx>_______________________________________________
>>>>>> CRISP mailing list
>>>>>> CRISP at nro.net
>>>>>> https://www.nro.net/mailman/listinfo/crisp
>>>>>
>>>>
>>>
>>>
>>> _______________________________________________
>>> CRISP mailing list
>>> CRISP at nro.net
>>> https://www.nro.net/mailman/listinfo/crisp
>>>
>>
>>
>> _______________________________________________
>> CRISP mailing list
>> CRISP at nro.net
>> https://www.nro.net/mailman/listinfo/crisp
>>
> 





More information about the CRISP mailing list