IANA Logo IANA Report on Recognition of LACNIC as a Regional Internet Registry

IANA Report

Subject: Recognition of LACNIC as a Regional Internet Registry
Date: 7 November 2002

The Internet Assigned Numbers Authority (the IANA), as part of the administrative functions associated with management of the Internet Protocol (IP) address space, is responsible for evaluating applications for approval of new Regional Internet Registries. ICANN has received an application for final approval and recognition of the Regional Latin-American and Caribbean IP Address Registry (LACNIC) as the fourth Regional Internet Registry.

Background

The role and responsibilities of ICANN/IANA in this area are defined in the Address Supporting Organization Memorandum of Understanding (ASO MOU) , and ICP-2 ("Criteria for Establishment of New Regional Internet Registries").

The ASO MoU provides that "[a]dditional RIRs may join in signing the MOU after they have been approved by ICANN." The ASO MOU specifies that, in carrying out this responsibility, "ICANN will develop requirements and policies for the approval of additional RIRs." Section 9 of the ASO MOU articulates seven basic requirements for new and existing RIRs.

In April 2001, after an open policy-development process and extensive public consultation, the Address Council submitted to the ICANN Board the "Criteria for Establishment of New Regional Internet Registries," as a more specific, minimum statement of guidelines and essential preconditions for the evaluation and approval of new RIRs. At the same time, the Address Council recommended that the Board authorize the ICANN staff to receive and evaluate applications for the recognition of new RIRs, using the criteria as a statement of minimum requirements.

In June 2001, the Board accepted the criteria document as a statement of essential requirements, supplementing Section 9 of the ASO-MOU, and acknowledged it as a framework for consideration of applications for recognition of new RIRs. At the same time, the Board authorized the President "to establish procedures and standards for the receipt of applications for recognition of new RIRs and for the evaluation of those applications, according to section 9 of the ASO-MOU and consistent with the requirements set forth in the Criteria" and "to devote sufficient resources . . . to the timely evaluation of any applications according to those procedures and standards." The ICANN President, with the assistance of the IANA, established procedures and standards for receipt and evaluation of new RIR applications.

On 28 November 2001, an application was submitted by the LACNIC organization for recognition, together with a detailed transition plan, including draft bylaws, policies, funding model, and staff resumes. On request of the ICANN President, the IANA staff conducted a preliminary evaluation; in March 2002 the President reported to the Board his conclusion that the application and transition plan constituted a reasonable basis for eventual recognition, though he noted that some adjustments would be necessary. Also in March 2002, the three existing RIRs (APNIC, ARIN, and the RIPE NCC) communicated a joint statement praising the excellent work of the LACNIC organization, noting the close cooperation between ARIN and LACNIC, and recommending a favorable response to the application by recognizing LACNIC's accomplishments thus far and according an interim status to LACNIC.

Consistent with the IANA's preliminary evaluation and the recommendations of the existing RIRs, the ICANN Board on 14 March 2002 gave provisional approval to the LACNIC application, with the expectation that the transition plan would be completed and a final application for recognition would be submitted. Over the following months, the IANA staff continued to consult with LACNIC and ARIN to monitor the transition of information and registration responsibilities, and to assist in finalizing the application for full recognition of LACNIC in conformance with the criteria set forth in the ASO MoU and ICP-2.

Since March, the LACNIC organization has supplemented and finalized its application, which has been carefully reviewed and evaluated by the IANA, according to the guidance and principles stated in the ASO MoU and ICP-2. On 30 October 2002, the President of ARIN communicated ARIN's favorable assessment of LACNIC's readiness for final approval and recognition.

Evaluation

In evaluating the LACNIC application for final approval and recognition, the IANA follows the guidelines and principles documented in the ASO MoU and ICP-2. Each of the ten ICP-2 principles is set forth in italics below, followed by the IANA's evaluation and analysis. Helpfully, the LACNIC application document tracks the numbered principles set forth in ICP-2.

1) The region of coverage should meet the scale to be defined by ICANN, given the need to avoid global address fragmentation.

The LACNIC application satisfies Principle 1. LACNIC will operate internationally, across a large geographic region of greater-than-continental size (see ICP-2: "The proposed RIR must operate internationally in a large geographical region of approximately continental size."; see also RFC 2050, page 3). Specifically, LACNIC's service region will cover the following countries and territories:

ARGENTINA GUYANA
ARUBA HAITI
BELIZE HONDURAS
BOLIVIA MEXICO
BRAZIL NETHERLANDS ANTILLES
CHILE NICARAGUA
COLOMBIA PANAMA
COSTA RICA PARAGUAY
CUBA PERU
DOMINICAN REPUBLIC SOUTH GEORGIA AND THE SOUTH SANDWICH ISLANDS
ECUADOR SURINAME
EL SALVADOR TRINIDAD AND TOBAGO
FALKLAND ISLANDS (MALVINAS) URUGUAY
FRENCH GUIANA VENEZUELA
GUATEMALA  

Based on consultation among the IANA, LACNIC, and ARIN, the above list omits two territories (Bouvet Island and St. Helena) that were mentioned in the November 2001 LACNIC application, in view of their distance from the South American continent.

LACNIC operates under a unified management, with a single location for registration operations. LACNIC's operations are in São Paulo, while its administrative headquarters are in Montevideo. Both the internal administrative and membership structures of LACNIC are designed, consistent with the existing RIR models, to avoid address space fragmentation, difficulties with inter-RIR coordination and cooperation, and community confusion.

2) The new RIR must demonstrate that it has the broad support of the LIRs (ISP community) in the proposed region.

The LACNIC application satisfies Principle 2. LACNIC has conducted extensive regional outreach and encouraged community input and involvement through its Open Policy Forum. A joint ARIN/LACNIC communication was sent to all ARIN members in the proposed LACNIC service region, and LACNIC has made independent efforts to contact and communicate with ISPs across Latin America and the Caribbean, including use of public mailing lists, its website, presentations at conferences and meetings, and direct contacts with individual local Internet registries (LIRs) and ISPs.

The IANA's review of the LACNIC efforts and the response of the relevant community within the region supports the conclusion that a very substantial majority are prepared to support LACNIC as the new regional RIR, to participate actively in its bottom-up policy-development processes, and to make the necessary financial commitment to support LACNIC's operations.

In addition, over the period of the transition LACNIC has demonstrated full capability to migrate existing ARIN service agreements to LACNIC.

3) Bottom-up self-governance structure for setting local policies.

The LACNIC application satisfies Principle 3. LACNIC has developed and implemented clearly defined procedures for the development of resource-management policies for its service region, as well as for participating in development of global policy recommendations through the Address Supporting Organization.

Drawing from the experiences and models of the ARIN, APNIC, and RIPE NCC bottom-up policy-development mechanisms, the LACNIC procedures are open and transparent, accessible to all interested parties, and capable of ensuring fair representations of all constituencies within the region. LACNIC has made a documented commitment to at least one open policy development meeting per year, accessible to all interested parties. LACNIC maintains a publicly archived mailing list for the discussion of polices. Members of the LACNIC community participate in working groups on particular policy-development topics.

Finally, LACNIC has made a commitment to host general assembly meetings of the ASO, as required in the ASO MOU.

4) Neutrality and impartiality in relation to all interested parties, and particularly the LIRs.

The LACNIC application satisfies Principle 4. LACNIC is an independent, not-for-profit, and open membership association. The submitted LACNIC bylaws and policies provide for equal treatment, fair distribution of resources, and impartial treatment of members and requestors. As reaffirmed in LACNIC's application:

All customers of LACNIC will be treated equally. The LACNIC policies and guidelines ensure neutral and impartial distribution of resources and non/discriminatory treatment of all members and all requestors. LACNIC is incorporated as an independent, not-for-profit and open bottom-up membership organization, as defined in our bylaws.

As confirmed by ARIN, LACNIC's activities during the transition period have demonstrated full compliance with these principles.

5) Technical expertise.

The LACNIC application satisfies Principle 5. LACNIC has demonstrated fully competent technical capabilities in all necessary areas, including:

  • production grade global Internet connectivity;
  • DNS servers to support Reverse DNS delegation;
  • suitable internal infrastructure for operational purposes; and
  • enough technically capable staff to ensure appropriate service levels to the its members, and to the Internet community.

LACNIC has operated with reliable, high-quality connectivity and the capability to operate reliable nameservers. It has also demonstrated the ability to administer the necessary invoicing and accounting systems and other elements of internal infrastructure. The IANA is pleased to note its conclusion that LACNIC's technical operation is impressive, well-designed, well-executed, and staffed by highly competent technical and operational personnel.

6) Adherence to global policies regarding address space conservation, aggregation and registration.

The LACNIC application satisfies Principle 6. Throughout the transition, LACNIC has operated under the ARIN policies that have historically been applicable to allocations and assignments to operators within its service region. Those policies are consistent with the global policies applicable to IP address allocation and assignment.

LACNIC has made substantial progress toward defining its own regional policies, and at its third annual meeting will consider adoption of policies that reflect ARIN's experience, as adapted to LACNIC's service region. LACNIC's policies are fully documented and publicly accessible on its website. These policies, and any changes to them, will be adopted according to LACNIC's open, bottom-up, member-driven policy development process. The provisions of the currently proposed policies appear to be consistent with and to respect the main goals of the IP address registry system (e.g., uniqueness, proper registration, aggregation, conservation, and fairness), demonstrating LACNIC's commitment to adhere to the IP addressing requirements of the global Internet, including global policies concerning conservation, aggregation, and registration.

LACNIC's longstanding active participation, as an emerging RIR, in the Address Supporting Organization, further demonstrates its commitment to adhere to applicable global policies.

7) Activity plan.

The LACNIC application satisfies Principle 7. LACNIC has submitted (and published) a detailed activity plan specifying activities that are clearly within the purview of an RIR. The LACNIC activity plan was developed through its open, community-based process, and appears to be accepted and supported by its prospective regional membership.

LACNIC's activity plan is not limited exclusively to IP address registration services. Its objectives also include:

  • Supporting the growth of the Internet in Latin America and the Caribbean.
  • Supporting the Latin American and Caribbean community in the development of procedures, mechanisms, and standards in order to assure the efficient assignment of Internet resources.
  • Promoting educational opportunities to its members in its technical and political areas of competence.
  • Proposing and developing public policies in its areas of competence.

LACNIC also submitted a comprehensive, three-phase transition plan, which was endorsed by the ICANN Board when it gave provisional recognition in March 2002. That transition plan has been successfully implemented and has now reached its final stages. The transition plan covered off- and on-site training of LACNIC registration personnel, technical exchanges between ARIN and LACNIC engineering staffs, and full collaboration between LACNIC and ARIN on legal, financial, administrative, and registration matters.

ARIN has reported favorably on LACNIC's execution of its transition plan, noting, for example, that at no time over the course of the transition did ARIN's second opinions on allocations and assignments differ with LACNIC's determinations.

Consistent with the guidance of ICP-2, LACNIC has committed not to be involved in forward domain-name assignment or administration.

8) Funding model.

The LACNIC application satisfies Principle 8. LACNIC is established as a not-for-profit association. Consistent with its activity plan, the LACNIC budget has been drawn up and published with support from the community of its prospective membership. Though initial funding is being provided by the Brazilian Internet Steering Committee (Comitê Gestor da Internet no Brasil.), LACNIC has adopted a fee structure that will enable it to be financially independent and supported entirely by its membership.

9) Record Keeping.

The LACNIC application satisfies Principle 9. LACNIC has established capabilities to maintain proper records of all registry activities, including the archiving of all information collected from local Internet registries in the process of making IP address space assignments. As specified in ICP-2, the official registration language for LACNIC will be English, including the relevant core registry documentation, records, archives, and information needed for operational audits.

10) Confidentiality.

The LACNIC application satisfies Principle 10. LACNIC has developed and implemented a comprehensive set of policies and procedures to ensure that the information its collects in the registration process will be kept in strict confidence, and used for registration purposes only. As stated in LACNIC's application:

All information that LACNIC receives from customers will be kept under strict norms of confidentiality and used for registration purpose only. In case of information is requested about a customer by another RIR or IANA, LACNIC will transmit this information under the same confidentiality agreement, but will not be transmitted to any other party unless explicitly agreed to in writing by the RIR/ISP served.

LACNIC establishes herein that Board Members are not allowed to participate in discussions where there are conflicts of interest. All board members and staff members are required to sign non-disclosure statements (see ANNEX VI LACNIC Non disclosure agreements).

In addition, LACNIC has provided a copy of its model non-disclosure agreement.

Conclusion

In sum, LACNIC has met all of the conditions specified in the ASO MOU and ICP-2. LACNIC's operations, policies, and bottom-up self-governance structure comply fully with the specified guidelines. LACNIC's technical operations and expertise are impressive. The transition plan has been satisfactorily executed. LACNIC's cooperation with ARIN has been exemplary, and ARIN has given its full endorsement to approval and recognition of LACNIC as an independent RIR.

Accordingly, the IANA concludes that LACNIC has met all the necessary requirements for approval and recognition.


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