Name: Jordi Palet Martínez
Email: jordi.palet@theipv6company.com
Organization: The IPv6 Company

Name: Jordi Palet Martínez
Email: jordi.palet@theipv6company.com
Organization: The IPv6 Company

This proposal updates the PDP in light of the doubts that have been raised regarding the mandatory nature of impact analyses.

It also establishes deadlines for these analyses, as currently no deadlines are specified.

This proposal updates the PDP in lighto cofnsider the doubts that have been raised regarding the mandatory nature of impact analyses.

It also uses the opportunity to establishes deadlines for these analyses, as currently no deadlines are specified.

Section 3.2.1. currently lists the functions of the PDP chairs, one of which is to receive comments from the LACNIC staff regarding different aspects of a policy proposal. Because receiving these comments is one of the functions of the PDP chairs, it follows that the staff must prepare such comments. Indeed, the LACNIC staff have been doing so for several years now, even though these comments are communicated to the community.

In a recent email exchange (https://mail.lacnic.net/pipermail/politicas/2020-August/005768.html), the staff pointed out that they do this at their own initiative, which raises doubts regarding the interpretation of the PDP and requires clarification.

They also noted that preparing impact analyses takes time and that this time needs to be variable. However, an earlier email (https://mail.lacnic.net/pipermail/politicas/2020-August/005765.html) included a study showing that the different time requirements do not appear to be reasonable, even in the case of simple proposals or new versions that include changes that are practically editorial in nature and that address comments from a prior analysis.

The proposal also seeks to solve situations where there have been delays or faults in the communication of these analyses. All of this has been more appropriately located in section 4, which addresses LACNIC's responsibilities and obligations.

SThe current text in section 3.2.1. currently lifers tso the functions of the PDP chairs, one of which is tonclude receiveing comments from the LACNIC staff regarding dvarifferentous aspects of a policy proposal. Because receiving tThese comments ismay onbe odif thfe furenctions ofrom the PDP chairs, impact foanallowyses th(IA) prepatred by the staff, mustwhich prepare such cnomt ments. Iiondeed, in the LACNICcurrent PDP and syetaff have been preparedoing so for severmalny years now, even withough these commensts areff communicating thedm to the community.

In a recent email exchange (https://mail.lacnic.net/pipermail/politicas/2020-August/005768.html), the staff pointed out that they dois this done at their own initiative, which raises doubts regarding the interpretation of the PDP and requires clarification.

They also notspecified that preparthings requimpact analyses takres time and that this time needmus to be variable. However, in an earlier email (https://mail.lacnic.net/pipermail/politicas/2020-August/005765.html), includedt wa study showingoted that the differences in the time requirementsd do not appear to be reasonable, even in the case of simple proposals or new versions that include changes that are practically editorial in nature and that address precisely comments from athe previorus analysies.

TheIt propoisal also sea quekstion tof solveing situations where there have been delays or fauprobltems in the communication of these analyses. All of this has been more appropriately located in section 4, which addresses LACNIC's responsibilities and obligations.

Finally, by not counting the weeks prior to the Public Policy Forums, the staff will not need to be involved in the preparation of impact analyses for any new proposals, which will discourage authors from publishing proposals too close to these events, except for new versions which are often (such as this very proposal) quite obvious and it might be said that they directly solve the weaknesses detected by the impact analysis.

3.2.1. Functions of the PDP Chairs
…
• To receive comments from LACNIC's Staff in relation to different aspects of a policy proposal. These comments may include, among others, comments on the wording of a proposal, cost of implementing a proposal, legal aspects, and where to include a proposal within the LACNIC Policy Manual.

4. Responsibilities and obligations of LACNIC

(added)
…

3.2.1. Functions of the PDP Chairs
…
• To receive comments from LACNIC's Staff in relation to different aspects of a policy proposal. These comments may include, among others, comments on the wording of a proposal, cost of implementing a proposal, legal aspects, and where to include a proposal within the LACNIC Policy Manual.

4. Responsibilities and obligations of LACNIC

(added)
…

3.2.1. Functions of the PDP Chairs
…
(eliminated)

4. Responsibilities and obligations of LACNIC

• LACNIC will publish an Impact Analysis (IA) of each version of a proposal (informing this on the Public Policy List), within a maximum of four weeks. In special cases, this period may be extended by a maximum of two weeks, justifying the reasons for doing so and with the presentation of a draft. The impact analysis will clarify the staff's interpretation of the proposal and may include, among others, notes on the implementation of the proposal, changes with respect to prior versions, comments, recommendations, the proposal’s impact on the registry system or other impacts, implementation cost, legal aspects and related references.
…

3.2.1. Functions of the PDP Chairs
…
(• To receive comments from the LACNIC Staff on various aspects of a polimcy proposal, in addition to the correspond)ing Impact Analysis.

4. Responsibilities and obligations of LACNIC

• LACNIC will publish an Impact Analysis (IA) of each version of a proposal (informing this on the Public Policy List), within a maximum of four weeks. In special cases, this period may be extreasonded ably a maeximum of two wendeksd, justifying the reasons for doing so and, if possible, with the presentation of a draft. The impact analysis will clarify the staff's interpretation of the proposal and may include, among others, notes on the implementation of the proposal, changes with respect to prior versions, comments, recommendations, the proposal’s impact on the registry system or other impacts, implementation costs, legal aspects and related references.
…
Considering the extraordinary workload involved in the events, the four-week period prior the Public Policy Forum will not be considered working days for the purpose of new proposals or new versions of proposals that include significant modifications. Regardless of this, LACNIC will attempt to comply with the requirement to publish the documents.

-

References:

• AFRINIC's PDP, which is relatively similar to LACNIC's, does not specify a deadline and states that the chairs may request AFRINIC to provide an analysis of the impact of the draft policy proposal. However, a year ago, given that the staff was not submitting these analyses, they publicly agreed (https://lists.afrinic.net/pipermail/rpd/2019/009844.html) that they would automatically send them with each new proposal/version. A policy proposal has also been submitted to make impact analyses mandatory and establishing a four-week deadline for new proposals and a two-week deadline for new versions.
https://afrinic.net/policy/manual
https://afrinic.net/policy/proposals/2019-gen-005-d1#proposal

• APNIC's PDP is very different and includes only five steps. Despite the fact that it does not include an impact analysis, these have been automatically prepared for some time.

• ARIN's PDP is also very different and does not explicitly include an impact analysis, although the impact analysis is presented when a proposal is accepted by the AC, usually within four weeks.

• RIPE's PDP is slightly different. However, the Discussion Phase specifies that the RIPE NCC must conduct and publish an impact analysis within a period of four weeks and does not allow this period to be extended.
https://www.ripe.net/publications/docs/ripe-710

• AFRINIC's PDP is relatively similar to LACNIC's. It does not specify a deadline and establishes that the chairs may request AFRINIC to provide an analysis of the impact of the draft policy proposal. However, a year ago, because the staff was not submitting these analyses, they publicly agreed (https://lists.afrinic.net/pipermail/rpd/2019/009844.html) that they would automatically send them with each new proposal/version. A policy proposal has also been submitted to make impact analyses mandatory and establishing a four-week deadline for new proposals and a two-week deadline for new versions of an existing proposal.
https://afrinic.net/policy/manual
https://afrinic.net/policy/proposals/2019-gen-005-d1#proposal

• APNIC's PDP is very different and includes only five steps. Despite the fact that impact analyses are not included in the PDP, these are being prepared automatically.

• ARIN's PDP is also very different and does not explicitly mention impact analyses. Despite this, an impact analysis is presented when a proposal is accepted by the AC, usually within four weeks.

• RIPE's PDP is slightly different. The Discussion Phase, however, specifies that the RIPE NCC must conduct and publish an impact analysis within a period of four weeks and does not allow this period to be extended.
https://www.ripe.net/publications/docs/ripe-710

• AFRINIC's PDP is relatively similar to LACNIC's. It does not specify a deadline and establishes that the chairs may request AFRINIC to provide an analysis of the impact of the draft policy proposal. However, a year ago, because the staff was not submitting these analyses, they publicly agreed (https://lists.afrinic.net/pipermail/rpd/2019/009844.html) that they would automatically send them with each new proposal/version. A policy proposal has also been submitted to make impact analyses mandatory and establishing a four-week deadline for new proposals and a two-week deadline for new versions of an existing proposal.
https://afrinic.net/policy/manual
https://afrinic.net/policy/proposals/2019-gen-005-d1#proposal

• APNIC's PDP is very different and includes only five steps. Despite the fact that impact analyses are not included in the PDP, these are being prepared automatically.

• ARIN's PDP is also very different and does not explicitly mention impact analyses. Despite this, an impact analysis is presented when a proposal is accepted by the AC, usually within four weeks.

• RIPE's PDP is slightly different. The Discussion Phase, however, specifies that the RIPE NCC must conduct and publish an impact analysis within a period of four weeks and does not allow this period to be extended.
https://www.ripe.net/publications/docs/ripe-710