[NRO-IANAXFER] JPNIC's comment for CRISP's initial draft

MAEMURA Akinori maem at nic.ad.jp
Mon Dec 29 13:07:58 CET 2014


Dear CRISP Team, 


Thank you for developing the response to be submitted to ICG on the IANA
stewardship transition for the number resources function.

JPNIC supports all three key elements of the proposal; They are
consistent with what JPNIC considers as important principles, which are
a) maintaining the continued stability of the IANA function b) ensuring
a scheme of accountability for the operation of the IANA function on the
number resources in meeting the needs of its stakeholders and c) have
pragmatic approach to meet the targeted deadline set by ICG.

With these as the basis, there are two aspects we would like to make
suggestions.

1. Description of existing scheme and proposed transition plan
   When integrating with proposals from other IANA functions, this
   proposal may appear minimal compared to names, while it is proposed
   based upon valid reasons.  It is important that communities outside
   the number resources understand this very clearly.

   We would like to request CRISP Team to double check, before
   submitting the proposal, that the following points are explicitly
   explained so that it can be clearly understood, especially by ICG
   members from the other communities as well as by NTIA.

   a. Unlike the IANA names function where NTIA approves changes in
      root zone file, there is no direct involvement by NTIA in
      operation of the IANA function on the number resources.
      Therefore, the transition of NTIA's stewardship has no direct
      effect on the operation of the IANA function on number resources.

   b. The only part NTIA is involved for the part of number resource,
      is conducting reviews on the service level of the delegated IANA
      function based on the IANA contract between NTIA and ICANN.  This
      is the part which is addressed and proposed by CRISP Team by the
      agreement to focus on service level IANA's number resources
      function, and Review Committee.


2. Comments related to proposed elements
   While we agree with the framework and the concept of each proposed
   elements, we believe the following points are important for
   respective proposed elements.

  a. Agreement with IANA function operator on the number resources
     In addition to maintaining the service level, we believe a scheme
     which ensures accountability on the service provision by IANA
     function operator for the number resources is important. This
     includes transparency of criteria and procedures, as well as a
     scheme which adequately addresses concerns/complaints raised about
     the service with clearly defined processes for remedies.

  b. Review Committee
     We believe it is important to ensure Review Committee provides
     adequate advice with a certain level of understanding on the IANA
     function on number resources.  Receiving advice on the service
     level with inadequate knowledge could even risk its service level
     to deteriorate.

   We therefore propose to have requirements for representatives to
   Review Committee to have sufficient knowledge in reviewing the
   IANA function on number resources. In addition, it may be useful
   to have rough guidelines on the role and key points of review, to
   share a common understanding and secure quality of the advice above
   a certain level.

   Lastly, we believe members of Review Committee must be selected by
   the community of each RIR region, such as in the form of elections
   conducted for NRO NC(ASO AC). NRO EC should not be involved in
   its selection to allow Review Committee to provide impartial
   advice to NRO EC, representing the RIR communities.


Best Regards,

MAEMURA Akinori, 
on behalf of JPNIC - Japan Network Information Center

-----
MAEMURA Akinori   General Manager, Internet Development Dept.
maem at nic.ad.jp      JPNIC - Japan Network Information Center



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