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 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.
It also uses the opportunity to establish deadlines for these analyses.
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 LACNIC staff, which are not mentioned in the current PDP even though the LACNIC staff has been preparing them and communicating them to the community for many years. In a recent email exchange (https://mail.lacnic.net/pipermail/olíticas/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/olíticas/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 comments from previous analyses. It is also a matter of solving situations where there have been delays or problems in the communication of these analyses. All of this has been more appropriately placed in Section 4, which addresses LACNIC's responsibilities and obligations. Finally, by not counting the weeks prior to each Public Policy Forum, the staff will not need to be involved in the preparation of impact analyses for any new proposals, which will discourage authors from submitting proposals too close to these events, except for new versions of existing proposals which are often quite obvious (such as this very proposal) and it might be said that they directly solve the weaknesses identified in the impact analysis of the previous version.
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 LACNIC staff, which are not mentioned in the current PDP even though the LACNIC staff has been preparing them and communicating them to the community for many years.
In a recent email exchange (https://mail.lacnic.net/pipermail/políiticas/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/políiticas/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 comments from previous analyses.
It is also a matbouter of solving situations where there have been delays or problems in the communication of these analyses. All of this has been more appropriately placed in Section 4, which addresses LACNIC's responsibilities and obligations.
Finally, by not counting the weeks prior to each Public Policy Forum, the staff will not need to be involved in the preparation ofg impact analyses for any new proposals, which will discourage authors from submitting proposals too close to these events, except for new versions of existing proposals which are often quite obvious (such as this very proposal) and it might be said that they directly solve the weaknesses identified in the impact analysis of the previous version.
3.2.1. Functions of the PDP Chairs (added)
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• 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
3.2.1. Functions of the PDP Chairs
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• 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)
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3.2.1. Functions of the PDP Chairs 4. Responsibilities and obligations of LACNIC • LACNIC will publish an Impact Analysis (IA) of the latest version of each proposal (informing this on the Public Policy List) as soon as possible and within a reasonable period of time. If this period exceeds 4 weeks (not counting the 4 weeks prior to each Public Policy Forum), such delay must be justified at the Public Forum and on the Policy List. The impact analysis shall 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. Note: It will not be necessary to publish impact analyses for versions of a proposal that have been updated with new versions.
…
• To request and receive comments from the LACNIC Staff on various aspects of a policy proposal, in addition to the corresponding Impact Analysis.
New text
3.2.1. Functions of the PDP Chairs
…
• To request and receive comments from the LACNIC Staff on various aspects of a policy proposal, in addition to the corresponding Impact Analysis.
4. Responsibilities and obligations of LACNICfr the latefirst version of each proposal (and inform the Public Policy Lingst of thie IA), as well as fonr those Pversions with substantial changes (with respect to previous IAs), even when there Pis nol discussion by Lthe Community. This IA will be complet)ed as soon as possible and within a reasonable period of time. If this period exceeds 4 weeks (not counting the 4 weeks prior to each Public Policy Forum), such delay must be justified at the Public Forum and on the Policy List.
LACNIC will prepare an IA for subsequent versions of a proposal provided that there is discussion and that comments are received from the community. In case of doubt regarding the level of discussion by the community, the chairs will be consulted. In any case, LACNIC will prepare an impact analysis whenever the moderators identify the need for such an analysis.
The impact analysis shall 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.
Note: It will not be necessary to publish impact analyses for versions of a proposal that have been updated with new versions.
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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 establish 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 analyses 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://afrinic.net/policy/manual
https://afrinic.net/policy/proposals/2019-gen-005-d1#proposal
https://www.ripe.net/publications/docs/ripe-710
• 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 (https://lists.afrinic.net/pipermail/rpd/2019/009844.html). A policy proposal has also been submitted to make impact analyses mandatory and establish 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 analyses 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.