comment on Consultation on Internet Number Resources Performance Standards

[Ron Wickersham]

On Sat, 8 Dec 2012, Avri Doria wrote:

> Hi,
>
> Just submitted a private comment on http://www.icann.org/en/news/public-comment/iana-kpis-20nov12-en.htm
>
> http://forum.icann.org/lists/iana-kpis/msg00000.html
>
> Would be interested to know if anyone thinks I missed the point.  I feel it is possible i did, since I thought the report was relatively vacuous.  But of course that means I might be the one who is vacant.
>
> I think there is still a day of so left if anyone else want to comment on this.  It isn't related to names, but it is related to IANA doing its function and putting out performance reports.  I thought it was sad that no one had sent in a comment.  So I tried.
>
> avri

hi Avri and all,

i am similarly confused by the "consultation" referred to in the document
(November 2012) _Consultation on Internet Number Resources Performance
Standards_, a short .pdf document.    within the document itself, there
appears to be no date other then November 2012, but my pdf reader shows
the document may have meta-data of "20Nov12".

i am also concerned that the participants within ICANN nor the implied
externat "consultantcy" were not identified.

most concerning, however, is the delay in publishing the public announcement
of allocations.  the data should be published simultaneously with the
allocations because filtering of unallocated (rogue self-assignments by
unauthorized spammers, crackers, etc. is good defense by ISP's and
end users.  when addresses are delegated, they should no longer be
blocked.   there is no explanation of why up to a two-business-day delay
should be a transparancy goal.

note that the case of IPv4 the performance indicator is to "begin"
allocation once trigger has been reached (with no requirement that the
actual allocation be done timely, so a delay of ten years would still
meet the 100% requirement so long as they "begin" the process immediately.

in the case of IPv6 and ASN numbers, there is to be an auto-ack ticket
system, and then (assuming the request meets policy) the delegation is
to be done, and after delegation the requester is to be notified.   the
performance measurement is silent if the IANA function declines to do the
requested allocation (and suggests that good performance is to limit
communication to no more than the two replies.

in this case (more frequent in the future than IPv4 delegations) there is
no justification for the public delay, since the updating of the registry
and the public announcement of the allocation could be made before the
requester is notified.

the transparancy of the process to the public is made difficult by the
policy to keep justification information submitted by requesters secret
so the information is never published.   so in the end, this is one of the
darkest closets of the workings of the Internet.

-ron