April 9, 2005

ICANN's Directors Once Again Shirk Their Responsbilities

I see that ICANN's Board approved several resolutions concerning IP address allocations.

Among these resolutions was one in which ICANN's Board unanimously adopted an "IPv4 Global Allocation Policy".

IP address allocation policy is the most crucial matter ever to come before ICANN's board.  IP addresses are the fuel on which the internet runs.  Without an IP address a person or computer is simply not part of the internet.  A policy that says who can get addresses and under what terms has a breathtaking impact on the shape of future internet growth.  Such a policy will have a significant impact on what enterprises survive and what enterprises fail.  The economic and social ramifications of IP address policy vastly overshadow the effects of ICANN's domain name policies.

Any policy regarding IP address allocation, therefore, ought to be made only with the greatest degree of lucidity and with the greatest attention to its technical, economic, and social effects.

Unfortunately, once again, ICANN fiddled and danced - and made jokes - and avoided the difficult, but necessary, work of actually engaging with the issues of this extremely important matter.

The resolution adopting this policy asserts the following "facts":

"the Board has considered the public comments that were submitted to the forum"

[the Board] "determined that existing procedures adequately address the issues that were raised

[N]o objection was raised by the Security and Stability Advisory Committee or other ICANN advisory bodies

There were four comments made on this policy during its comment period.  All of these comments cited substantial concrete concerns about fundamental aspects of the policy.

ICANN has never responded to any of these comments.  There is no reason to believe that ICANN's Board or any board member is even aware of those comments.

I challenge ICANN to demonstrate that any board member ever read these comments, much less considered them when making his or her decision on the IPv4 address policy.

As for the board's assertion that "existing procedures adequately address the issues that were raised".  Hogwash.  There is no indication that the board or any of its members actually reached this conclusion except by being led to it by the nose by "staff".  And the assertion is also factually incorrect.  Not one of the concerns raised is covered by any existing procedures.

And finally - as for objections by the so-called "Security and Stability Advisory Committee":  Because that committee operates in total secrecy how can anyone tell what that committee says or does?

Once more we have the members of ICANN's board acting as nothing more than mindless monkeys who respond with affirmative noises to whatever is put in front of them.

There is no indication that any ICANN Board member actually performed his or her duty to make an independent and informed judgment on what is, in truth the most critical, and in fact the only truly technical, matter ever to come before ICANN: IP address allocation policy.

ICANN has many flaws, but perhaps its greatest flaw is that the members of its Board of Directors again and again and again insult the internet community and violate their duties by refusing to take the time to try to comprehend and understand the issues put before them and refusing to make their own independent decisions.

ICANN's Board, both as a body and as individuals, has demonstrated once again that even when compared to the extremely lax standards of the past board's of Enron, Tyco, and MCI/Worldcom, ICANN's board and its members comes out gravely wanting.

ICANN's directors should be ashamed of themselves.  Not even one director has indicated that he or she is treating his or her role with the kind of attention and respect that the community of internet users deserves and which the law requires.

Update: April 13, 2005:

Below is the entire body ofmaterial given to the board to rebut the public comments on this critical policy.  No member of the board asked for any clarification or raised any other question or concern.

THE SUBSTANCE OF THE OBJECTIONS RAISED TWO ISSUES IN DIFFERENT FORMS. THE FIRST WAS THAT THERE WAS NO MECHANISM FOR RECOVERING ADDRESS ALLOCATIONS, AND IANA'S ANALYSIS OF THIS WAS THAT THE PROVISIONS FOR SUBSEQUENT ADDRESS BLOCK ALLOCATIONS ALREADY TAKE INTO ACCOUNT ALL ELEMENTS OF THE UTILIZATION OF THE ADDRESS SPACE. SO IF A GIVEN RIR IS NOT USING THEIR SPACE EFFECTIVELY, THAT WILL SHOW UP IN A SUBSEQUENT ALLOCATION REQUEST. THE SECOND FORM OF THE COMPLAINT IS THAT THERE WAS INSUFFICIENT OVERSIGHT OF THE RIRS. AND AGAIN, IANA HAS REVIEWED THIS AND SAID THAT THE IAB HAS DELEGATED RESPONSIBILITY FOR MANAGING THE IPV4 ADDRESS SPACE TO IANA; THEREFORE, IANA HAS THE RESPONSIBILITY TO WORK WITH THE RIRS TO RESOLVE ANY QUESTIONS THAT MAY ARISE FROM A PARTICULAR REQUEST. THE SUPPORTING ISSUE, WITH A MINOR REQUEST FOR CHANGE, HAS BEEN RESOLVED THROUGH ADDRESS ALLOCATION NOTIFICATION PRACTICES. SO IT'S NO LONGER AN OUTSTANDING REQUEST FOR A CHANGE.

I was amused to see the explict transfer of ultimate authority over IP address space policy out of ICANN's hands and into that of the IAB.  The ICANN-IANA-IAB-NTIiA shell game about who is in charge has continued for far too long.

Posted by karl at April 9, 2005 6:11 PM