[rpd] Re: [NRO-IANAXFER] IANA Numbering Services SLA Draft Call for Comments

[Douglas Onyango]

All,
My comments on the Draft SLA for the IANA Numbering Services document are below.

Background (A): ICANN, by virtue of a contract with the US Government,
has for some time been performing
the functions of the Internet Assigned Numbers Authority (IANA).

I find the use of "some time," in a binding document improper and
setting bad precedent. I suggest we replace it with actual figures -
unless we can't ascertain the facts.

Background (G) The Parties each commit individually to abiding at all
times by the results of their respective Policy Development Processes.

The development, implemented and compliance to RIR Policy Development
Process has been the remit of the RIR and its community. I am not sure
why we want to change this, and what bearing it could possibly have on
the draft SLA. I also don't see the ramifications of noncompliance
anywhere.
I suggest we drop this on account of relevance and enforceability.

4.2.1 - a. The RIR will submit an initial request for Internet Number
Resources to the Operator by electronic mail (e-mail).

The shape and form of this email is not specified here, neither is the
discretion to prescribe it left with any party. I suggest we allow the
operator to prescribe a mutually acceptable format. We could further
include a mechanism for communicating this format in case it changes.

4.2.1 - c -i: allocate the requested Internet Number Resources to the
RIR within four (4) Business Days from the date of the acknowledgment
of receipt of the initial request by the Operator, or receipt of the
additional information if requested, whichever is later;

My interpretation of this is that 100% of all requests much be
completed within 4 business days after acknowledgement or receipt of
additional information - without deviations. (1) this doesn't appear
to cater for those times when multiple request for additional
information will be made (2) I am also not sure how practical it is to
respond to all requests within 4 business days, especially when
requests are at their peak. Given the very ominous ramifications of
failure to meet this target, I suggest we ascertain practicality and
also consider reducing the compliance to say 85-90% of requests.

6.2. Obligation to Issue Reports: The Operator shall perform the
function as described in Article 4 and shall be obliged to yearly
issue reports illustrating its compliance with the obligations
described in Articles 4 and 6.1.

Issuing reports is an operational matter and I see no reason why we
should wait a whole year for this. The reports, especially the
compliance to response and fulfillment time for requests should be
made available much sooner so as to facilitate immediate remedial
action. I suggest we either submit two reports with one monthly
operational report and then some kind of annual reports, or just have
a compliance reports every 90 days.

8.3 Performance of Reviews: The Operator must comply with the request
by providing the requested information within working days.

253 working days can be considered working days too!! I suggest we
change this to more accurately capture the intent. My suggestion is 5
working days. This should be sufficient given that most of this data
should already be available and the only requirement is putting it in
whatever format it has been requested