Name: Izumi Okutani

Organization: Consolidated RIR IANA Stewardship (CRISP) Team

Submission ID: 133

We would like to thank the ICG for its efforts in coordination and combining the proposals
from the three operational communities into a single proposal.
Please find the response from the CRISP Team as attached. The response has been sharedwith the number resources community in advance on the <ianaxfer@nro.net> mailing list.
In general, in addition to two questions we received, we observe that a few community
members who had strong opinion about the CRISP Team response have expressed theircomments.
While these individuals have submitted their own comments to the ICG, you are able to see
the feedback to the CRISP Team response at: https://www.nro.net/pipermail/ianaxfer/
Best Regards,
Izumi Okutani and Nurani Nimpuno
Chair and Vice Chair, the CRISP TeamCRISP Team Response to the IANA Stewardship Transition
Coordination Group (ICG) Call for Public Comment on IANA
Stewardship Transition Proposal

Introduction
The Consolidated RIR IANA Stewardship (CRISP) Team provides thefollowing responses to the call for public comment on the combined IANA
Stewardship Transition Coordination Group (ICG) proposal. The CRISP team hasreviewed the combined proposal incorporating the proposals from the threerespective operational communities and responds to the questions below accordingly.
These comments are focused on the Internet numbers component of the combined ICG
proposal.
The CRISP Team is a team composed of three representatives from each of thefive RIR regions. It was established in 2014 to consolidate the output of discussions in
the regional communities on the IANA stewardship transition, and to develop a single
proposal from the Number Community. This proposal was submitted to the ICG in
January 2015. The CRISP Team will remain in place until the completion of thetransition process. For more details, see: https://www.nro.net/nro-and-internetgovernance/iana-oversight/consolidated-rir-iana-stewardship-proposal-team-crispteam

1. Completeness and clarity: Is the combined proposal complete? Each of
the operational community proposals contains aspects to be completed in
the future when the proposal is implemented. Is the combined proposal
specified in sufficient detail such that it can be evaluated against the
NTIA criteria?
Yes, we believe that the draft ICG proposal is complete and clear.
Stewardship structures and mechanisms for all of the IANA functions aredescribed in the draft proposal, as are the principles and criteria needed to
implement the proposal for each of the IANA functions.
The protocol parameters component clarifies that that the existing mechanism
for stewardship of the protocol parameter registries can continue in the absence of
NTIA oversight, while the names component describes in detail the structures to beestablished around a "Post-Transition IANA" (PTI) including the PTI Board,
Customer Standing Committee (CSC), IANA Function Review Team (IFRT), and thecriteria for the IANA Function Review (IFR).
For the IANA Numbing Services, the proposal specifies that a number of items
will need to be implemented prior to the expiry of the NTIA contract, specifically the
finalization of the SLA, establishment of the Review Committee, and resolution of the
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management of the IANA-related Intellectual Property Rights (IPR). Quoting the
Number Community proposal, the ICG draft lays out the principles that will underlie
the SLA and the role and the composition of the Review Committee.
The ICG has noted one exception, specifically that the names proposal iscomplete only on the condition that specific ICANN-level accountability mechanisms,
currently under development by the Cross Community Working Group on Enhancing
ICANN Accountability (CCWG), are fulfilled as specified in the names proposal.
We note that CWG and CCWG are coordinating to ensure that the CCWG's
output will take account of any dependencies identified in the CWG proposal andrelating to the names related functions. We trust that any issues with regard to thiscoordination will be resolved in a timely fashion.
With regards to the IANA Numbering Services, there are no dependencies on
the accountability mechanisms developed by the CCWG. The Number Community
proposal establishes robust accountability mechanisms via a Service Level Agreement(SLA) between the Regional Internet Registries (RIRs) and the IANA Functions
Operator (Operator) and the existing structures ensuring the RIRs' accountability totheir communities. The proposal for stewardship of the IANA Numbering Services iscomplete with no other external dependencies.
For completeness and clarity specific to the IANA Numbering Services, basedon the number community proposal, the draft SLA text and the Review Committee
draft charter are already under development and discussion in the Number
Community, with agreed documents expected ahead of implementation of the full
proposal. This demonstrates that the proposal provides details sufficient to prepare
for the implementation of the IANA stewardship transition.

2. Compatibility and interoperability: Do the operational community
proposals work together in a single proposal? Do they suggest any
incompatible arrangements where compatibility appears to be required?
Is the handling of any conflicting overlaps between the functions resolvedin a workable manner?
Yes, we believe the operational community proposals work together in asingle proposal, with no issue of compatibility and interoperability. While thethree communities did not produce identical proposals on how to handle the
IANA functions, each of the three IANA function is basically independent withminimum overlap. In areas where potential incompatibility were anticipated,such as on Intellectual Property Rights (IPR) and establishment of the Post
Transition IANA (PTI), we believe all three communities have worked to ensurethat the structures and mechanisms proposed in their submissions do not conflict.
We would like to stress that the Number Community commits to continue
coordinating with the other operational communities during, and after the
implementation phase to ensure that the requirements are met as described in the ICG
proposal.
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Following are some observations by the CRISP Team on the issues concerning
IANA Intellectual Property Rights (IPR) and establishment of the Post-Transition
IANA (PTI) are described below.
Intellectual Property Rights (IPR):
In the course of developing the combined proposal the ICG identified apotential compatibility issue regarding handling of the IANA trademarks and theiana.org domain name. We agree with the ICG's assessment: as long as the names
community and the protocol parameters community can accommodate therequirements specified in the Number Community proposal as part of theirimplementation, there is no obstacle to the implementation of all three proposals.
The Number Community stated a clear expectation that "both [the IANA
trademarks and the iana.org domain] are associated with the IANA Numbering
Services and not with a particular IANA Numbering Services Operator. Identifying anorganization that is not the IANA Numbering Services Operator and which will
permanently hold these assets will facilitate a smooth transition should anotheroperator (or operators) be selected in the future."
The proposals from the other two communities do not make a specificproposal with regard to the IANA trademarks and domain name. In response to the
ICG inquiry, the protocol parameters community stated that it had no objection to the
IETF Trust serving as the repository for the trademarks and domain name associatedwith the provision of the IANA services, an acceptable solution stated in the Number
Community proposal. The IETF Trust formally acknowledged their willingness tohold the intellectual property rights relating to the IANA function, including the IANA
trademark and the IANA.ORG domain name.
We note the ICANN Board statement by Steve Crocker on 15 August 2015,
supporting the ICG proposal and stating that ICANN is prepared to transfer fullownership of the IANA-related trademarks and ownership of the iana.org domain to aneutral third party mutually agreed among the operational communities. The CRISPTeam chairs have responded that we believe that this allows the implementation of the
IPR-related parts of the IANA Stewardship transition to be consistent with the
Number Community proposal.
We believe the ICANN Board statement further strengthens the combined
IANA Stewardship Transition Proposal.
Establishment of the Post Transition IANA (PTI):
The names community proposes the creation of a new organization to manage
all IANA functions, namely the PTI. Such a structure was not proposed by the othercommunities. However, we do not believe this creates an incompatibility for the othercommunities. The Number Community proposal for the RIRs to sign an SLA withICANN is still possible to implement, and therefore still workable.

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Further, as a part of the composition of the PTI, the names community
proposes creation of additional committees aimed at reviewing service levels andproviding operational oversight (namely, the IFRT, special IFRT and the CSC).
The Number Community requires no additional reviews or organizational
structures beyond the Review Committee that is specified in the Number Community
proposal. However, because the scope of the activity of these new structures is limited
to the IANA naming function, we see no overlap nor do we see any incompatibility.

3. Accountability: Do the operational community proposals together
include appropriate and properly supported independent accountability
mechanisms for running the IANA functions? Are there any gaps inoverall accountability under the single proposal?
The CRISP Team observes that, when combined, the proposals from thethree communities include appropriate and properly supported independentaccountability mechanisms for management of all of the IANA functions. Eachof the IANA functions is accountable to different, independent operational
communities, and overall accountability is therefore addressed by the
combination of the accountability mechanisms defined by the three operational
communities. We do no observe any gaps under the ICG proposal.
The Number Community's approach to addressing accountability is based ona contractual relationship between the RIRs and the IANA Numbering Services
Operator and the ability to chose another Operator if the need should arise. This
relationship is governed by a Service Level Agreement (currently in development),
based on 11 IANA SLA Principles outlined in the Number Community proposal. ThisSLA is currently being developed and discussed and contains contractual provisions
ensuring that the Operator meets specified service level requirements.
This is based on the RIR community's well-tested, longstanding, communitydriven and mature accountability mechanisms and processes. When consideredalongside the accountability mechanisms proposed by the names and protocol
parameters communities, the ICG proposal clearly ensures that the IANA Functions
Operator will be strongly held accountable to the global community. Further, thepotential accountability gap for the names related IANA function is dependent on, andaddressed in, the work of the CCWG. We observe CWG and CCWG are closelycollaborating to ensure all issues are covered by clarifying area of accountability
issues related to the names function, to be covered by its respective groups.

4. Workability: Do the results of any tests or evaluations ofworkability that were included in the operational community proposals
conflict with each other or raise possible concerns when considered in
combination?
We support the ICG assessment that the three proposals constituting the
combined proposal are individually and collectively workable. The day-to-day

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operation of each of the IANA functions are independent, and this proposal does
not propose any new technical or operational processes that may raise concerns
when considered in combination. Further, we do not observe elements of the
proposal the other two IANA functions would cause concerns on workability for
the IANA Numbering Services when considered in combination. The CRISPTeam observes that the operational community proposals do not conflict witheach other in terms of workability when considered in combination.
In terms of other elements relating to implementation to the number
community proposal, the drafts of the SLA and the Charter of the Review Committee
do not have any conflicts or incompatibility with the ICG proposal.
As noted in the Number Community proposal there are areas of overlap in the
IANA registry system today, where coordination is necessary to avoid conflicts. Thereis a track record of effective collaboration among the operational communities incoordinating on such existing issues and there are no changes to these areas as aresult of the ICG proposal.
Considering the Number Community component of the proposal on its own, it
builds on the methods and processes that have long been in place, which are well
documented, and which are operationally effective for the IANA Numbering Services,which should not affect the other two functions on its workability.

5. Do you believe the proposal supports and enhances themultistakeholder model? If yes, please explain why. If not, please explain
why and what proposal modifications you believe are necessary
The CRISP Team strongly believes, in agreement with the ICG, that the
proposal supports and enhances the multistakeholder model. Each of theoperational communities has proposed a mechanism of oversight by theirrespective communities relevant to each of the IANA functions. All three of theoperational communities have proposed transition of the IANA functions
stewardship to entities that those communities recognize as representing them.
These communities, while there are difference in the process and how thecommunities operate, they all share in common to be open to and reflect the
input of a wide group stakeholders.
As stated in the Number Community proposal, this stewardshiptransition is an important step in acknowledging the maturity, stability andsuccess of the multistakeholder governance model.
On the IANA Numbering Services, we agree with the description of the RIR
structure, its long-established governance mechanisms, and open participatory
process for policy development. The CRISP Team developed the Number Community
proposal following an open and transparent process to which all stakeholders could
contribute. The process ensured that anyone with an interest was given theopportunity to participate in the discussion and compilation of the Number
Community proposal. The CRISP proposal introduces improvements in transparency
and accountability related to performance of the IANA Numbering Functions,Page 5 of 10

enhancing the Number Community's multistakeholder processes through theestablishment of the Review Committee, which will facilitate members of the five RIR
communities providing advice to the RIRs on the service level of the IANA Numbering
Services and performance of the Operator.

6. Do you believe the proposal maintains the security, stability, andresiliency of the DNS? If yes, please explain why. If not, please explain
why and what proposal modifications you believe are necessary.
Yes we believe the proposal maintains the security, stability, andresiliency of the DNS. It is our assessment that no other elements in the ICG
proposal, compromise the security, stability, and resiliency of the DNS as
pertained to the administration of the special-purpose “IN-ADDR.ARPA” and“IP6.ARPA” DNS zones".
While not directly relevant to the DNS, in the wider context of the number
resources component of the IANA functions, the Number Community believes thecurrent operation of the IANA Numbering Services is secure, stable, and resilient. To
maintain this current state, we have ensured that our proposal does not suggest any
changes that would affect the security, stability, or resiliency of the IANA Numbering
Services. There are no changes proposed for the operation of the IANA Numbering
Services. We are further ensuring the service level to be maintained through the SLA.

7. Do you believe the proposal meets the needs and expectations of the
global customers and partners of the IANA services? If yes, please
explain why. If not, please explain why and what proposal modifications
you believe are necessary. Please indicate if you are a customer or partnerof the IANA services.
Yes we believe the proposal meets the needs and expectations of the global
customers and partners of the IANA services.
While we do not represent the other two operational communities, we
believe that the bottom-up processes used to develop all three community
proposals, have resulted in proposals that meet the needs and expectations of the
global customers and partners of the IANA services. The combined ICG
proposal defines a mechanism which the respective global customers andpartners of the each of the IANA function will have oversight on the services,with periodic review of its performance.
The Number Community is the customer of the IANA Numbering Services. The
Number Community has often expressed its satisfaction with the current Operator’s
management of the IANA Numbering Services, specifically the Operator’s effective
implementation of policies developed by the community and efficient provision of the
IANA Numbering Services to the RIRs. This proposal has been developed by the
Number Community, as the customer of the IANA Numbering Services, and meets that
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community's need for continuity and stability in the operation of the IANA Numbering
Services. This need is met by solidifying the Operator’s accountability to the Number
Community.

8. Do you believe the proposal maintains the openness of the Internet? Ifyes, please explain why. If not, please explain why and what proposal
modifications you believe are necessary.
Yes, we believe the proposal maintains the openness of the Internet. Bytransitioning the oversight mechanism to entities representing the operational
community, based on open, bottom-up and inclusive processes, it enhances the
openness of the Internet from the current mechanism of oversight by the NTIA,
where the involvement of the global Internet community was limited.
We do not identify any elements in the ICG proposal that would
jeopardise the openness of the Internet, but rather that it enhances it throughtransitioning the oversight of the IANA functions to the three operational
community, with open and inclusive participation.
With reference to the IANA Numbering Services, an open Internet relies on theeffective implementation of policies developed via open, transparent, and bottom-up
processes, and the transparent and coordinated distribution and registration ofInternet Number Resources. The Number Community has a long-standing history of
open, transparent and bottom-up policy-making and operational processes (including
the transparent publication of all registration information). By building on the
structures developed by the Number Community, the ICG proposal ensures that inthis regard the openness of the Internet is maintained.

9. Do you have any concerns that the proposal is replacing NTIA’s rolewith a government-led or inter-governmental organization solution? If
yes, please explain why and what proposal modifications you believe arenecessary. If not, please explain why.
No, it is clear that this proposal does not replace the NTIA’s role with agovernment-led or inter-governmental organization solution. None of the entities
which will have oversight of the IANA functions are governments, nor are theyinter-governmental organizations.
The Number Community proposal places the RIRs in the role currently
occupied by the NTIA. The RIRs are not-for-profit organizations that are accountable
to the community. The Number Community is open to anyone who wishes tocontribute and includes participants from Internet stakeholder groups including
operators, civil society, business, the technical community, and governments. Open,
community-driven and consensus-based policy development processes mean that no
single stakeholder group has a dominant role in policy-making.

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It is our assessment that the two other operational community proposals also
demonstrate a commitment to the multistakeholder model, with bottom-up, community
driven processes. It is these consensus-driven processes that have allowed theInternet to develop as an unparalleled engine of economic growth and innovation todate. We further believe that the consensus-driven, multistakeholder model is the bestmodel for maintaining an open, resilient, and secure Internet, and for minimizing any
risk of potential undue government influence.

10. Do you believe that the implementation of the proposal will continue
to uphold the NTIA criteria in the future? If yes, please explain why. If
not, please explain why and what proposal modifications you believe arenecessary.
Yes we believe the implementation of the proposal will continue to upholdthe NTIA criteria in the future by transitioning the oversight to the operational
communities. We strongly believe that the operational communities will ensure
the checks and balances to maintain the NTIA criteria.
All the criteria set by the NTIA are consistent with the principles for theoperational communities of the IANA functions, with long-standing, provenexperience over time, from the early days of the Internet until today.
We support the analysis in the Internet Society paper “Perspectives on
the IANA Stewardship Transition Principles” outlining how the NTIA criteria
are consistent with the values and principles of the Internet community:
https://www.internetsociety.org/sites/default/files/IANA-Transition-Perspectives20150728-en.pdf
As outlined above, we believe that the NTIA criteria build on the fundamental
Internet principles that have made the Internet one of the most successful
technologies in history. These principles have been developed, supported andimplemented by the operational communities to date. The transfer of the oversight of
the IANA services to those operational communities who are the customers of each of
the IANA functions, allows those communities to continue to act as a guardian ofthose principles. The bottom-up, community-driven model proposed for the
management of the IANA services is also the best protection against capture by asingle set of stakeholders, government or otherwise.
With regards to the Number Community, the core decision-making of the RIRs,
lies with its community and members, through well-tested mature processes. Any
attempts to change these criteria by any party, will be subject to review by the
Number Community, which has a proven record in defending the principles on whichthese criteria are based.
We observe the IETF and ICANN also have similar open and inclusive
participation models. There may be some variations amongst the models with regard
to particular mechanisms for implementation; but the success of community-based
checks and balances is a common factor of all the models.
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11. Do you believe the ICG report and executive summary accuratelyreflect all necessary aspects of the overall proposal? If not, please explain
what modifications you believe are necessary.
We believe that all necessary aspects of the Number Community proposal
are covered in the ICG report including ICANN continuing as the Operator, theSLA between the Operator and the five RIRs, establishment of the Review
Committee and management of IANA-related IPR.
We also observe that the ICG report and executive summary also coverpost-transition oversight and accountability mechanisms for the other two IANA
functions.

12. Do you have any general comments for the ICG about the proposal?
We thank the ICG for its efforts in managing the timelines as well as
developing the proposal, which has adequately reflected the proposal from theoperational communities.
The CRISP Team strongly supports the transition of the stewardship of the
IANA functions. We support the criteria set by the NTIA as . We observe this as away forward, which leads IANA functions to have its oversight mechanism based on
the global Internet community as the customers of the IANA functions, based open,
bottom-up and inclusive mechanism. It is consistent with the values cherished by the
Number Community and how the Internet operates today.
Its details are described in the paper published by the Internet Society (ISOC):“Perspectives on the IANA Stewardship Transition Principles”
https://www.internetsociety.org/sites/default/files/IANA-TransitionPerspectives-20150728-en.pdf
It is our assessment that the combined ICG proposal demonstrates acommitment to the multistakeholder model, with bottom-up, community driven
processes for all three IANA functions. It is these consensus-driven processes
that have allowed the Internet to develop as an unparalleled engine of economic
growth and innovation to date. We further believe that the consensus-driven,multistakeholder model is the best model for maintaining an open, resilient, andsecure Internet, and for minimizing any risk of potential undue influence of any
single stakeholder, government or otherwise.
We observe that the process leading to the public comment by the ICG
has been bottom-up, based on input from the three operational communities,
and open to anyone interested in the process to participate.

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Further, we support the process developed by the ICG, which itself is abody with representatives from a wide range of stakeholder, has respectedbottom-up process followed by each of the operational communities. We feel that
the ICG has adequately integrated the proposals, including elements of the
Number Community proposal that has reached consensus within the Number
Community.
In this light, if any substantial changes are made in the next version of the
ICG proposal, we note that additional consultation within our community would be
required to determine whether the Number Community supports any such changes.
We hope not to face such situation where possible, so as to minimize potential impact
on the overall timelines.
The CRISP Team would like to emphasise the importance of this transition totake place in a timely manner, consistent with the set timelines. The CRISP Teamstrongly encourages all operational communities, and the CCWG, to continue
working to meet the published ICG timelines, including the implementation timelines.
For the IANA Numbering Services, we trust and work together with RIRs whereappropriate, in preparing its implementation to meet the targets set within the
Number Community and the global timelines set by the ICG.
Finally, based on the collaborative spirit expressed among the threeoperational communities, we trust we will continue to work efficiently towards
finalizing the proposal for the transition.

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