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[Comment-Aso] Re: Draft Proposal for the MoU-based ASO

August 12, 1999

Interim Board of Directors
ICANN - Internet Corporation For Assigned Names and Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292


Dear ICANN Interim Board Members,

We, the Board members of the Regional Internet Registries (RIRs) would
like to respond to recent correspondence from The European
Telecommunications Standards Institute (ETSI) regarding the "Draft
proposal for the MoU based Address Supporting Organization (ASO) that we
submitted to ICANN in July 1999.

A number of matters raised by ETSI's correspondence raise significant
concerns  that we would like to share with ICANN and the community
of interested  parties.

As we are all aware, Internet Address allocation policies represent one
of the most challenging public policy areas confronting ICANN over the
coming years. We all recognize the fundamental role played by address
allocation policies in terms of defining access to the communications
medium itself in almost every communications technology. As a corollary,
any Internet address allocation policy has far reaching, and potentially
quite dramatic business, technological and social implications. These
extend far beyond the commercial drivers referenced by ETSI in their
consideration of the commercial opportunities that may form part of a
future deployment of IPv6-based systems and services. The challenge
posed to ICANN is to create structures and processes within ICANN that
can be vehicles for the diversity of interests to be represented, and
allow for a broad range of potential policy outcomes to be aired and
discussed within a balanced and open forum.

It is appropriate in this note to elaborate on some of the thinking that
has been part of the drafting of the ASO proposal to which ETSI is
referring. When drafting the structure of the ASO proposal we were
confronted with two schools of thought; one, to create an all-embracing
ASO that included direct representation from every party who had an
interest in address allocation policies, and the second, to create an
ASO that was directly constructed upon the self-regulatory, bottom-up,
open membership model of the Regional Internet Registries, and use ICANN
itself as the means of including the broader constituency of interest.

To elaborate on these alternatives, the first potential direction was to
ensure that the ASO itself adequately encompassed all potential
interested parties directly within the ASO framework itself. In
developing this proposal further it was quickly apparent that the set of
potential interested parties numbers in the hundreds of thousands, if
not higher. There are industry standards bodies, technical coordination
bodies, various regional industry bodies, bodies representing
historically influential industry sectors, telecom industry sector
bodies, computer industry bodies, national industry bodies, vendor
associations, technology industry forums, governments, in various
guises, international governmental coordinating bodies, industry service
bodies, to name but a few.  The international trend to deregulation of
the communications industry has resulted in a significant number and
diversity of players without the imposition of a rigid international and
regional hierarchy based on various forms of international treaties. All
of these bodies within the increasingly deregulated communications
sector, and also all those bodies who are consumers and exploiters of
communications services, have a legitimate interest in the outcome of
global Internet address allocation policies. To attempt to create such a
body which would properly fold in such a diversity of interest, and to
attempt to create a structure with appropriate checks and balances to
ensure fairness and openness in the operation of the body, is seen as
being an extremely ambitious task for an ASO. If it were to succeed in
such a task there is the likely outcome that such a body would
inevitably attempt to usurp the role of ICANN itself.

The second school of thought was to create an ASO which allowed the fair
and open participation of those bodies which are the current recipients
of allocated addresses through the self-regulatory structures of the
Regional Internet Registries.  In so doing we are mindful that the
complete panoply of interested parties are not directly represented
within an ASO, but rather are represented by being members of ASO member
organizations, similar in manner to the DNSO constituencies. We do see
that the broader structures of ICANN itself strive to pull together the
massive diversity of interests which collectively are the Internet
today, and there is little to be gained, and perhaps much that could be
regretted in the future, if such a direction were mindlessly replicated
within the ASO proposal. The consequent tensions for control over
Internet address allocation policy formulation between the two bodies
would, no doubt, be mutually destructive, since both groups would be
asserting primacy of role due to their breadth and depth of
constituency. Such an outcome is an anathema to the RIRs and the
membership of the RIRs. We are not interested in proposals that places
sectional interests before all others, as the resultant tensions are
often irreconcilable.

Our intention in drafting the ASO proposal as it stands is to create a
structure which fits well within the overall framework of ICANN, and
allows those parties with a direct interest in Internet address
allocation practices to participate in the activity of the ASO, and
through the ASO, to participate in the activities of ICANN. Other
parties have a broader set of interests within ICANN, or may have a more
indirect interest in the global address allocation policies adopted by
ICANN, and may choose to express such an interest via the ICANN
Governmental Advisory Council, ICANN's At Large constituency, or via the
Protocol Supporting Organization. We recognize that ICANN's role is
limited to global policies relating to Internet addresses, and that
ICANN, and its supporting organizations make no claims whatsoever to
usurp other bodies undertaking similar roles within other communications
technologies, such as for telephony or Local Area Network Media Access
Control addresses.

We commend ETSI for being one of the first telecom industry bodies to
express an interest in Internet address allocation policies, and in so
doing we would also welcome many other industry, trade, governmental and
consumer-based bodies at international, regional and national levels to
express a similar level of interest in this activity. We believe that
through such diverse expressions of interest we can generate global
address allocation policies that are expressive of our needs and
priorities as a global community. But in encouraging such participation
we do not see the ASO in its own right as being the sole vehicle for to
carry such a broad agenda of determining social, business, and
technology policy for a global community. We strongly believe that it is
ICANN itself which is the appropriate vehicle for such a critical and
important agenda.

Rather than attempting to assert undue and improper influence within the
ASO by usurping the balance between the membership of the RIRs and the
ASO, we suggest to ETSI, and all other interested parties, a course of
action which recommends that they become active participants within the
scope of the Regional Internet Registries' activities, and assist in the
efforts of such bodies to create sustainable and stable self-regulatory
regional service bodies. If such parties have a broader set of interests
in ICANN's activities than is encompassed by the Regional Internet
Registry's activities, we would strongly recommend that they also
participate in other relevant ICANN supporting bodies within the
structure and framework adopted by ICANN for the operation of such

Our intent in formulating the RIR ASO proposal is to propose what we
believe is a framework that is consistent with a direction of working
cooperatively to address ICANN's agenda. We see this ICANN agenda as one
of creating an appropriate forum for the development of Internet
policies that accurately reflect the characterization and present and
future needs of the community at large. We firmly reject a notion that a
body should participate in ICANN merely to exercise control or
influence, or bring to undue prominence to sectional or historical
interests to the determent of a broader set of legitimate interests.

We believe that the RIR ASO proposal is one which does not attempt to
directly address by sole virtue of its structure of representation every
issue that could impinge on global Internet address allocation policies.
We see the ASO proposal as being a component of the ICANN framework, and
furthermore we see the RIR ASO proposal as it stands today as being
entirely consistent with that framework, allowing a balance of interests
to be fairly and properly represented within the overall task of policy

We would appreciate your consideration of these additional perspectives
when reviewing the ASO proposal, and are strongly supportive of the
notion that it is a central role for ICANN itself to serve as the
vehicle for determining consensus across the Internet community.

Submitted on behalf of

     the American Registry for Internet Numbers (ARIN),

     the Reseaux IP Europeens Network Coordination Centre (RIPE NCC), and

     the Asia Pacific Network Information Centre (APNIC).

by their respective Boards and Executive Committees.