LACNIC Staff's Interpretation of the Proposal
Author: Jordi Palet Martinez
Applicability:
This proposal introduces changes to the PDP.
Modifications to the current text:
The proposal modifies sections “3.2.1. Functions of the PDP Chairs” and “4. Responsibilities and obligations of LACNIC.”
Proposed 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 LACNIC
● ACNIC will publish an Impact Analysis (IA) for the first version of each proposal (and inform the Public Policy List of the IA), as well as for those versions with substantial changes (with respect to previous IAs), even when there is no discussion by the Community. This IA will be completed 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 chairs 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.
…
LACNIC Staff Comments:
1) LACNIC believes that an impact analysis is a useful tool that provides additional input for policy discussions. However, the chairs and the community can —and in fact it is desirable— begin to discuss each proposal even if the corresponding impact analysis is not yet ready.
2) An impact analysis is relevant provided that it serves as useful input for the community's discussion. We believe that a discussion process where only the author of a policy and LACNIC participate but without community participation is irrelevant. We have noticed that, when an impact analysis exists but there is no community feedback, authors rush to draft new versions of the proposal without waiting for feedback from the community.
3) We do our best to make sure that any impact analysis we publish is complete, yet on occasion additional information may be obtained from various sources (staff, members of the community, other RIRs, etc.) which would be relevant to share. In such cases, we will update the impact analysis that has already been published, or simply share this information during the Forum/on the Policy list.
4) LACNIC is the first to be interested in preparing impact analyses and in the community being aware of the challenges and risks that a proposal could represent for our systems and processes. Therefore, regardless of whether this is specified in the PDP, LACNIC will continue to prepare impact analyses.
5) We will not provide specific recommendations because we wish to know whether the community believes that this issue should be specified in the PDP.
Recommendations:
1) No additional recommendations.
Impact of the policy on the registry and/or other systems
The approval of this proposal would not affect LACNIC's systems, but it would increase the time commitment required from the staff. Implementation would be immediate.
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.
Rationale (Describe the problem you intend to solve)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.
Current text3.2.1. 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.
…
-
TimetableImmediate implementation
References• 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
LACNIC 34 online (05/10/2020)
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.
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.
Current text3.2.1. 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)
New text3.2.1. Functions of the PDP Chairs
…
• To 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 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.
Additional informationReferences:
• 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
Immediate implementation
References-
Presented at:LACNIC35 (11/05/2021)
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.
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/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 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 placed 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.
Current text3.2.1. 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 the LACNIC Staff on various aspects of a policy proposal, in addition to the corresponding 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 six 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 that an event involves, 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.
…
-
TimetableImmediate implementation
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 thta it does not include an impact analysis, these are being 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
-
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.
Current text3.2.1. 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)
New text3.2.1. 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 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.
Additional information-
TimetableImmediate implementation
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 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.
https://www.ripe.net/publications/docs/ripe-710
LACNIC 38 (04/10/2022)
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/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 comments from previous analyses.
It is also about 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 preparing 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.
Current text3.2.1. 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)
…
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 LACNIC
• LACNIC will publish an Impact Analysis (IA) for the first version of each proposal (and inform the Public Policy List of the IA), as well as for those versions with substantial changes (with respect to previous IAs), even when there is no discussion by the Community. This IA will be completed 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.
…
-
TimetableImmediate implementation
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 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. https://www.ripe.net/publications/docs/ripe-710
Presented at:LACNIC 39 (10/05/2023)