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Letter of Intent on ICANN / NRO MoU

  • To: <aso-mou-comments@xxxxxxxxx>
  • Subject: Letter of Intent on ICANN / NRO MoU
  • From: "Debecker J.L." <debecker@xxxxxxx>
  • Date: Tue, 11 May 2004 10:46:54 +0200

Dear colleagues,

As the currently proposed MoU is very close to the earlier text, ETNO wishes
to re-submit its Expert Contribution EC053 that we released last year, as a
reply to the call for public comments

For your convenience, EC053 is copied below in ASCII format.

Best regards,

Leo Debecker
Executive Manager, Operations


October 2003

ETNO Expert Contribution on ICANN reform

Executive Summary

ETNO welcomes the initiative of the Regional Internet Registries (RIRs) to
reinforce their collaboration through a new structure (NRO).
But ETNO would like to see further clarification concerning the draft
agreement between RIRs, in order to clearly understand the differentiation
between operational activities and policy development.
In ETNO's view, policy issues should not fall under the responsibility of
the NRO structure to avoid any conflict of interest.

As part of the address community, ETNO (footnote 1) appreciates the
opportunity offered to comment on the Regional Internet Registries (RIR)
draft for public comment on ICANN reform, published on 23rd September 2003.

In their draft open letter to ICANN, ETNO notes that "the RIRs acknowledge
the benefits of the ICANN structure in terms of providing an open framework
for the coordination of a number of critical Internet administration
functions, and have determined that they will continue to work within this
framework and support ICANN in this endeavour".

ETNO is satisfied with the intention of the RIRs to reinforce their

These intentions constitute a positive evolution in the reinforcement of the
stability and coherence of IP address management, and ETNO supports these

Our in-depth analysis of the draft agreement between RIRs, however, raises
some questions that demand further clarification. 

1. The Number Resource Organisation seems to be a structure mixing
operational activities and policy development.  These two different
activities need a clear distinction in order to avoid conflicting interests.

A good way around this would be to restrict the NRO to non-policy issues
(technical cooperation between RIRs, service contracts, etc., and to have an
ASO council, distinct from the NRO organisation with a clear responsibility
on policy issues. 

2. "The NRO Executive Council shall ratify or reject proposed global IP
number resource policies and the NRO Number Council shall be responsible for
the provision of advice on such proposed policies". 
According to the proposed selection process, the NRO Executive Council is
selected by the RIRs Board, and cannot be representative of the addressing
community as a whole. ETNO is of the opinion that a ratification of a policy
proposal or even an involvement of this Council in the policy development
process is inappropriate. 

ETNO suggests that this task should be organised under the responsibility of
the ASO council. In order avoid any conflict of interest, it is essential
that no member of the ASO council be an employee or a Board member of an

Regarding the Global Policy Development Process, ETNO considers that the
appropriate body to ratify a consensus position (Step 4) is the ASO Address
Council and not the Boards of the RIRs. 

In the same way, the appropriate body for consultation by the ICANN Board
(Step 8 to 12) should be the ASO Address Council, and not the RIRs.

(1) The European Telecommunications Network Operators' Association is
representing 41 major companies from 35 European countries, providing
electronic communications networks over fixed, mobile or personal
communications systems. ETNO's primary purpose is to establish a
constructive dialogue between its member companies and actors involved in
the development of the European Information Society to the benefit of users.
More information on ETNO can be found at: www.etno.be

ETNO Expert Contribution EC053 (2003/10)

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