[CRISP-TEAM] Observations about the third version of the SLA

Izumi Okutani izumi at nic.ad.jp
Wed Nov 25 11:16:16 CET 2015

Dear CRISP Team,

Below are my observations about the changes made in the 3rd version of the SLA, for discussions at the call today.
I have two clarification questions on Articles 11 & 12. 

It would be very helpful if the CRISP Team members who are RIR staff and worked on the draft could provide clarification at the call.


Explanatory Notes
Nothing substantial. Editorial changes.

Deleting of two phrases. Did not observe implications which affects the SLA principles.

Article 1: Definitions and Interpretation
Nothing substantial. Editorial changes.

Article 2:
Separation of Policy Development and Operational Roles

 - 2.1 Operational Role of the Operator is weaker obligation than ver.2 but reasonable and does not affect the SLA principles.
   "The Operator shall use its best efforts to coordinate with operators of other IANA services, if any.": is required -->shall use its best efforts
 - 2.3 IANA Numbering Services Staff: Changes provide better clarity.

Article 4: Distribution of services provided to RIRs
 - 4.1-4.3 All changes seem to be intended to reflect the practical issues in the services provided to RIRs. Details of this level were not defined by the SLA principles.
 - It is not within the scope of the CRISP Team to review it, as long as it satisfies the needs of the RIRs
 - Changes in 4.4 Registry Data provides better environment for the RIRs to review the data, which is consistent with the SLA principles, and support this change

Article 6: Transparency and accountability
 - 6.1 Implementation of Global Policies Provides better clarity
 - 6.2 Obligations to Issue Report provides more details on report on the Performance Standards, Survey and Security and System Audits. It gives and opportunity for wider community to understand the status of the IANA Numbering Services and support the changes

Article 7: Security requirements
 - It is not clear why some clauses which seem helpful in maintaining security requirements such as IFO to have external audits are deleted. However, this level of detail is not within the scope of the SLA principles and no inconsistencies observed

Article 8: Review of IANA Numbering Services
 - This section is important and relevant the the SLA principles
 - Changes described mainly tries to address it in Article 6, which is well articulated. No concerns/inconsistencies observed.

Article 11: Continuity of operations
 - It seems to have weaker obligation to the operator " The Operator agrees to exercise *best efforts and cooperation* to effect an orderly and efficient transition to a successor operator"
 - Would like to understand why and clarification that this maintains the stability of the operation at the event of changing the IFO

Article 12: Intellectual property rights and rights over data
 - Would like to understand the changes better: whether this does not hinder RIRs' ability to change the IFO due to IPR related issues, especially on data/systems.

Noted that no changes are made on "Article 9: Failure to perform" and  "Article 10: Term and termination", which are important for the SLA principles.

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