If you’re reading this shortly after it was posted, you’ve got about 17 hours to comment on an important change being proposed at ARIN, the manager of Internet Protocol addresses for the North American region.
ARIN is proposing a new “Policy Development Process.” (Sound familiar?) A step by step description of the proposal can be found here. The essence of the change is that the ARIN Advisory Council would manage and dispose of all policy proposals. Currently, anyone can put forward a proposal on ARIN’s open list and get them discussed at meetings. The purpose of this change is to streamline and make more efficient its policy development process, which (the advocates of change argue) currently produces “too many similar or overlapping proposals,” too much confusion, technically unsound proposals, and too much uncontrolled flux in text as policies are being discussed.
The new PDP proposal is an example of the increasing formalization of IP address policy making. This trend is to some extent inevitable. Everyone interested in Internet governance needs to understand that and be attuned to the consequences.
If (as is likely) the new process is adopted, ARIN’s Advisory Council will become a gatekeeper for policy proposals. It will have all the familiar advantages and disadvantages of a gatekeeper. On the plus side, it will reduce the amount of information people have to deal with and make it possible to apply uniform procedures and standards to all proposals. It will act as a clearinghouse for amendments, filter out some obvious junk proposals and institute a division of labor.
But all these advantages have their flip side: the PDP will concentrate decision making authority in a smaller group of people. Like the Committee and Subcommittee system in the U.S. Congress, this structure inherently provides a choke point that permits a few people to snuff out ideas before they can gain a hearing. And although ARIN’s PDP provides for a petition process to appeal arbitrary decisions, the overall effect is to raise the costs and procedural barriers for anyone who makes dissident or challenging policy proposals. Another thing to keep in mind about setting up gatekeepers of this sort is that once they are established they are virtually impossible to get rid of. Those who are empowered by the gatekeeping function simply do not give up that power once they get used to it.
What makes this seemingly obscure, bureaucratic topic of interest is the increasing importance of Regional Internet Address Registries in Internet governance. The policy development process of ARIN – and all the other RIRs – will take on increasing significance in the future. As the Internet runs out of IPv4 addresses, there are pressures to migrate to IPv6, secure the routing system, and implement a market or transfers for IP addresses. This means that RIRs are likely to inherit the unenviable position of ICANN as the center of many governance and policy controversies. No wonder then that is has, like ICANN, developed a formal “policy development process.”
The technical managers of the Internet, with their constant talk of “community” and “consensus,” do not always seem to be mentally equipped for this change. Public policy is all about working out distributional issues – who gets what share of the pie. As IP addresses become scarcer and more strategic resources, policy making by RIRs is bound to become less consensusal and more like….well, ICANN: controversial, political, occasionally deadlocked by contending special interests. In this kind of an environment, a small group that claims to be able to discern “consensus” and to discern the “needs” or “will” of “the community” needs to be watched closely, and suspiciously.
In the meantime, if you have time to comment (ARIN sent out the call for comment a mere two days before the deadline posted the original proposal two weeks ago, but public discussion on the PPML about the proposal has only occurred in the past few days), it makes sense to minimize the new AC’s gatekeeping role while maximizing its more neutral, efficiency-enhancing clearinghouse functions. In particular, one should be able to advance and discuss policy proposals on its public policy mailing list. You can post your opinions to arin-ppml@arin.net no later than 5 PM EDT, Friday, 9 May 2008.
While the risks of the AC becoming a gatekeeper are noted, I would also have concern about the ARIN _staff_ (which btw now includes a former NTIA official as it's Executive Director of Government Affairs and Public Policy) becoming too influential in the proposed PDP. This is a point often made about ICANN's PDP. The AC is an elected body, if it fails to serve the community, “the bums can be thrown out” eventually. However, as the proposed PDP is currently worded, a proposal can be effectively delayed by ARIN staff reviews early in the process, forcing the sponsor to petition just to get it in front of the AC for discussion, further editing, and review by the community on the PPML.
The point of the staff's proposal review should only be to ensure that the proposal is understandable. Similar to Congressional staffers, they should help the sponsor draft the proposal language but have no ability to influence whether the proposal is actually discussed by the AC and broader community. Obviously, accomplishing this kind of distributed proposal drafting can be challenging, but there are folks exploring how to do this kind of exercise transparently and inclusively in a public policy environment, e.g., PublicMarkup.org A tool like this could even be used further upstream in the PDP by the AC during its draft policy editing phase.
Actually, it seems that the term 'gatekeeper' is used in a manner that is inflammatory.
If you mean that the Advisory Council (AC) has an ability to forward or not forward a policy proposal to the Board of Trustees (BoT), that role and duty has resided with the AC since its inception.
In the last iteration (current) of the more formalized PDP, a petition process and thresholds for surmounting them…allowing an author to bypass the AC was introduced and that same feature remains in the new PDP process under discussion.
The nuance, IMO, is that the proposals coming from whatever source will first go to the ARIN staff for review of language, grammar, and understandability in general. That a proposal would not pass this 'test', the disposition seems in doubt. The proposal says the author would have to petition to get it to the AC for review in its original state.
Alternatives ask that this 'hurdle' be removed and in the event, the staff cannot convince the author to 'smith' the words to their understanding, the proposal might go directly to the AC rather than the petition process.
I actually favor the later alternative, but I am most interested in hearing other input.
I see very little concern otherwise.
Bill Darte
ARIN Advisory Council