CRISP - Process Concerns

[Guru Acharya <gurcharya@xxxxxxxxx>]

I would like to highlight the following concerns about the process adopted
by CRISP, which disqualify it from satisfying the criteria of following a
bottom-up multi-stakeholder process as mandated by the NTIA.

1) Top-down composition and selection of CRISP team: The CRISP team was a
closed group selected by the RIR executive committee by way of an interview
process. Interested participants were excluded from the working group if
they did not successfully qualify for the interviews conducted by the RIR
executive committee. The selection criteria for the candidates was not made
public by the RIR executive committee. This is important given that
non-CRISP participants were excluded from the decision-making process.

2) Top-down decision-making by the CRISP team: While the general public was
invited to provide comments for the draft proposals prepared by CRISP, they
were excluded from the decision-making process. Commenters were merely
informed that their input had either been accepted or rejected by the CRISP
team after due consideration. Notably, non-CRISP participants were not
allowed to contribute to CRISP's tele-conferences or CRISP's internal
mailing list, where the actual decision-making took place. Mere
consultation of the general public without their involvement in the
decision-making process does not constitute a bottom-up multi-stakeholder
process.

3) Lack of information and transparency: The CRISP team had two mailing
lists. The mailing list used internally by the CRISP team was a closed
mailing list that was not publicly archived till after the proposal was
finalised. This resulted in community evaluation of the process and
proposal in the absence of requisite information about the reasons for any
decisions.

4) Refusal to deal with essential aspects of the proposal: The CRISP team
refused to deal with essential aspects of proposal such as the contract
renewal process, contract duration, jurisdiction, arbitration process,
review process, high level details of the contract, intellectual property
rights, charter of the review team and service levels. The CRISP team cited
these essential aspects as outside the scope of the CRISP mandate. If the
CRISP mandate is indeed so limited, then its incomplete proposal should be
returned to the RIR community with the suggestion of expanding the mandate
of the CRISP team. Note that the charter of the CRISP team, which was
prepared by the NRO EC in a top-down manner, does not suggest that such
essential aspects should be excluded from the proposal. This limited
interpretation of the agenda and issues by the CRISP team is against the
ethos of a bottom-up multi-stakeholder process.

Regards,
Guru Acharya