| Authors | |
|---|---|
Name: Jordi Palet Martínez |
Name: Jordi Palet Martínez |
| Summary | |
This proposal updates the PDP to consider the doubts that have been raised regarding the mandatory nature of impact analyses. It also uses the opportunity to establish deadlines for these analyses. |
This proposal updates the PDP to consider the doubts that have been raised regarding the mandatory nature of impact analyses. |
| Rationale (Describe the problem you intend to solve) | |
The current text in section 3.2.1. refers to the functions of the PDP chairs, which include receiving comments from the LACNIC staff regarding various aspects of a policy proposal. These comments may be different from the impact analyses (IA) prepared by the staff, which are not mentioned in the current PDP and yet have been prepared for many years, with the staff communicating them to the community. In a recent email exchange (https://mail.lacnic.net/pipermail/politicas/2020-August/005768.html), the staff pointed out that this is done at their own initiative, which raises doubts regarding the interpretation of the PDP and requires clarification. They also specified that this requires time and that this time must be variable. However, in an earlier email (https://mail.lacnic.net/pipermail/politicas/2020-August/005765.html), it was noted that the differences in the time required 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 the previous analyses. It is also a question of solving situations where there have been delays or problems 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. |
The current text in section 3.2.1. refers to the functions of the PDP chairs, which include receiving comments from the LACNIC staff regarding various aspects of a policy proposal. These comments may be different from the impact analyses (IA) prepared by the staff, which are not mentioned in the current PDP and yet have been prepared for many years, with the staff communicating them to the community. |
| Current text | |
3.2.1. Functions of the PDP Chairs 4. Responsibilities and obligations of LACNIC (added) |
3.2.1. Functions of the PDP Chairs |
| New text | |
3.2.1. Functions of the PDP Chairs 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 reasonably extended, 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. |
3.2.1. Functions of the PDP Chairs |
| Additional information | |
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. • 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. |
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| References | |
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• 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. |