A Comment on Policy For Allocation of IPv4 Blocks to Regional Internet Registries

[Danny Younger <dannyyounger@xxxxxxxxx>]

I have the following concerns:

1.  We know from RFC 2050 that Internet address space is distributed with 
certain goals in mind, one of which is conservation.  The document under 
consideration, while describing a policy governing the allocation of IPv4 
address space from the IANA to the Regional Internet Registries, fails to 
detail policies necessary to ensure conservation -- necessary policies such as 
those pertaining to the recovery of unused address space do not appear in this 
document, nor is it anywhere posited that the IANA has the requisite authority 
to recover resources that have already been allocated.  As such, the document 
should be returned to the originating body for further work.

2.  Re:  "If IANA does not have elements that clearly question the Regional 
Internet Registry's projection, the special needs projected for the following 
18 months, indicated in Item A above, shall be considered valid."    At issue 
is the protocol to govern special needs situations when the IANA does have 
elements that clearly question the RIR's projection.  Who is authorized to rule 
on the matter?  Will it be the IANA or the IAB (from whom the IANA may seek 
advice) or in such instance must the wishes of the RIR be respected?  Is 
perhaps the issue elevated to ICANN?  The document fails to clarify the roles 
of the respective parties to a sufficient degree.  Ambiguity in a global policy 
document does not serve the Internet community well and as such this document 
should be returned to the originating body for further clarification prior to 
adoption.

3.  Transparency -- it is not clear whether submitted "justifications" of 
special needs are to be handled as an internal administrative matter (which 
will not be made public) or whether the requirements of transparency also apply 
to the IANA.  ICANN should clarify whether, under the terms of its bylaws, the 
IANA is deemed a constituent body that is subject to those transparency 
requirements cited in the ICANN bylaws.


                
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