Re: [CSC-Review] (Updated draft) Proposed RAP reviewed by ICANN
Hi Bart, hi all. I’m sort, but I’ve not had a chance to look through the draft report yet. (Yes, I know, we were asked to do this today.) However, I have had a chance to look at the draft CSC Remedial Action Procedures and I do have some concerns. 1. Paragraph 1, first sentence: The starting point is not correct: it is all about “[reviewing] individual complaints with a view to identifying any patterns of poor performance by the IANA Functions Operator in responding to complaints of a similar nature.” Only if there is systemic failure would this lead to initiating the RAP (paragraph 6 of the scope of responsibilities). The primary element of the scope is to address [currently] “poor performance” (paragraphs 3 & 4 of the scope in the current charter), but this does not feature in the current draft. 2. Paragraph 1, sentences 3 & 4 (The IANA Naming Function Contract … PTI Performance Issue.) and section I.a): I think that this misses the intention of the CSC and its engagement in resolving performance issues. While I certainly accept that, when initiated, the PTI and ICANN Boards will want to be kept informed (and agree that this is appropriate), the intention is to ensure that operational issues are addressed and resolved at the appropriate level. First step is for the CSC to discuss the issue with the IANA team to identify the nature of the problem and its cause. This is about looking for issue resolution. So, the first step is for the CSC to raise the issue with the PTI Liaison on the committee. My concern is that the new draft is missing out on this important first step: the CSC identifies that there appears to be a problem and asks the liaison to explain the issues and what they intend to do about it. (This is the “notification” step in the illustrative RAP in the charter.) Incidentally, I think that it is the PTI Board (because it is the role of PTI) that is responsible for overseeing the first stages of the response process. There is no reason why the charter would prevent them from alerting the ICANN Board, but I do not think that this is something that should be dictated in the charter or the RAP. It is an internal matter for ICANN & PTI and ICANN is represented on the PTI Board, so I would expect the ICANN Board to be updated as appropriate. I do see a serious issue in muddling up responsibilities between the two Boards. It seems to me to be important for the CSC to know who is responsible at any stage in the process and for action to be taken at the appropriate level. 3. Clause I.a): I think that the first step is that the CSC has noted a continuing failure in PTI to meet the SLA and asked the liaison to [investigate and] explain what has happened and what they are doing about it (an action plan). It is not deciding to review a complaint except in a very specific case. 4. Clause II.a): The next step is then to allow an agreed time for the PTI team to implement their action plan. I do not think that it is appropriate for the Charter to require the CSC to copy to “the President of ICANN’s GDD”: that is an internal ICANN-PTI issue. Incidentally, I also find the definition of the Remedial Action Request Report rather overdone. CSC has identified an issue. It should not be required to provide a rationale for initiating the next stage of the RAP other than to identify the SLA failure (or the systemic failure) and point to a failure to remedy the performance issue, pointing to the action plan identified by the operational under I.a). 5. While the remainder of the document seems to be close to what was originally specified, it does seem to be over-specified. III.a) is a case in point: it does not allow for the CSC to escalate because the CSC has rejected the Corrective Action Plan, for example: if the CAP has long delays in the response process due to allocation of resources, surely it is appropriate for the CSC to escalate to the level that can address the resources issue? 6. I’m sure it is not intended, but the escalation steps seem to start the process again, imposing a serious work load on the CSC. Of course, there should be a chance for CSC to question what is being done about the issues. But there should be some clear communication within the different levels of the escalation process so that it does not need to keep on going over the background. That said, I would expect all issues to be addressed by the operator (PTI), with the main reason for escalation to ICANN being that resources necessary for PTI to carry out its job are not being made available. As it stands (and as I read the document), I would worry about this draft being used as the basis for the charter review. Thanks Martin From: Elaine Pruis [mailto:elainepruis@gmail.com] Sent: 06 February 2018 16:40 To: Martin Boyle <martin.boyle.hertford@ntlworld.com>; Austin, Donna <donna.austin@team.neustar>; Drazek, Keith <kdrazek@verisign.com>; Abdalla <ceo@kenic.or.ke> Subject: Fwd: (Updated draft) Proposed RAP reviewed by ICANN Hi, Please find attached the draft CSC Remedial Action Procedures. This is after several iterations within the group and with ICANN Org. We hope to meet to finalize before the Feb 15 CSC monthly meeting. Elaine ---------- Forwarded message ---------- From: Marilia Hirano <marilia.hirano@iana.org> Date: Fri, Feb 2, 2018 at 3:10 PM Subject: (Updated draft) Proposed RAP reviewed by ICANN To: Elaine Pruis <elainepruis@gmail.com <mailto:elainepruis@gmail.com> >, Allan MacGillivray <allan.macgillivray@cira.ca <mailto:allan.macgillivray@cira.ca> >, "Gannon, James-1" <james-1.gannon@novartis.com <mailto:james-1.gannon@novartis.com> >, Byron Holland <byron.holland@cira.ca <mailto:byron.holland@cira.ca> > Cc: Amy Creamer <amy.creamer@icann.org <mailto:amy.creamer@icann.org> >, Naela Sarras <naela.sarras@iana.org <mailto:naela.sarras@iana.org> >, Trang Nguyen <trang.nguyen@icann.org <mailto:trang.nguyen@icann.org> >, Samantha Eisner <Samantha.Eisner@icann.org <mailto:Samantha.Eisner@icann.org> >, Bart Boswinkel <bart.boswinkel@icann.org <mailto:bart.boswinkel@icann.org> >, Maria Otanes <maria.otanes@icann.org <mailto:maria.otanes@icann.org> > Hello RAP WG, I have attached the newest draft RAP containing the updates that we agreed on during our last call on January 23rd. We have taken all of your input into consideration, re-worded some statements, and added the formal escalation points to the PTI Board and the ICANN Board. I hope this draft meets the needs of the CSC and can be presented to the broader group in the next meeting, but we are open to more iterations if need be. Thank you and have a great weekend! Marilia
Martin, Thank you for the comments. Suggest Elaine informs the CSC sub-group Kind regards, Bart From: CSC-Review <csc-review-bounces@icann.org> on behalf of Martin Boyle via CSC-Review <CSC-review@icann.org> Reply-To: Martin Boyle <martin.boyle.hertford@ntlworld.com> Date: Friday 9 February 2018 at 14:43 To: 'Elaine Pruis' <elainepruis@gmail.com>, "'Austin, Donna'" <donna.austin@team.neustar>, "'Drazek, Keith'" <kdrazek@verisign.com>, 'Abdalla' <ceo@kenic.or.ke>, "CSC-review@icann.org" <CSC-review@icann.org> Subject: Re: [CSC-Review] (Updated draft) Proposed RAP reviewed by ICANN Hi Bart, hi all. I’m sort, but I’ve not had a chance to look through the draft report yet. (Yes, I know, we were asked to do this today.) However, I have had a chance to look at the draft CSC Remedial Action Procedures and I do have some concerns. Paragraph 1, first sentence: The starting point is not correct: it is all about “[reviewing] individual complaints with a view to identifying any patterns of poor performance by the IANA Functions Operator in responding to complaints of a similar nature.” Only if there is systemic failure would this lead to initiating the RAP (paragraph 6 of the scope of responsibilities). The primary element of the scope is to address [currently] “poor performance” (paragraphs 3 & 4 of the scope in the current charter), but this does not feature in the current draft. Paragraph 1, sentences 3 & 4 (The IANA Naming Function Contract … PTI Performance Issue.) and section I.a): I think that this misses the intention of the CSC and its engagement in resolving performance issues. While I certainly accept that, when initiated, the PTI and ICANN Boards will want to be kept informed (and agree that this is appropriate), the intention is to ensure that operational issues are addressed and resolved at the appropriate level. First step is for the CSC to discuss the issue with the IANA team to identify the nature of the problem and its cause. This is about looking for issue resolution. So, the first step is for the CSC to raise the issue with the PTI Liaison on the committee. My concern is that the new draft is missing out on this important first step: the CSC identifies that there appears to be a problem and asks the liaison to explain the issues and what they intend to do about it. (This is the “notification” step in the illustrative RAP in the charter.) Incidentally, I think that it is the PTI Board (because it is the role of PTI) that is responsible for overseeing the first stages of the response process. There is no reason why the charter would prevent them from alerting the ICANN Board, but I do not think that this is something that should be dictated in the charter or the RAP. It is an internal matter for ICANN & PTI and ICANN is represented on the PTI Board, so I would expect the ICANN Board to be updated as appropriate. I do see a serious issue in muddling up responsibilities between the two Boards. It seems to me to be important for the CSC to know who is responsible at any stage in the process and for action to be taken at the appropriate level. Clause I.a): I think that the first step is that the CSC has noted a continuing failure in PTI to meet the SLA and asked the liaison to [investigate and] explain what has happened and what they are doing about it (an action plan). It is not deciding to review a complaint except in a very specific case. Clause II.a): The next step is then to allow an agreed time for the PTI team to implement their action plan. I do not think that it is appropriate for the Charter to require the CSC to copy to “the President of ICANN’s GDD”: that is an internal ICANN-PTI issue. Incidentally, I also find the definition of the Remedial Action Request Report rather overdone. CSC has identified an issue. It should not be required to provide a rationale for initiating the next stage of the RAP other than to identify the SLA failure (or the systemic failure) and point to a failure to remedy the performance issue, pointing to the action plan identified by the operational under I.a). While the remainder of the document seems to be close to what was originally specified, it does seem to be over-specified. III.a) is a case in point: it does not allow for the CSC to escalate because the CSC has rejected the Corrective Action Plan, for example: if the CAP has long delays in the response process due to allocation of resources, surely it is appropriate for the CSC to escalate to the level that can address the resources issue? I’m sure it is not intended, but the escalation steps seem to start the process again, imposing a serious work load on the CSC. Of course, there should be a chance for CSC to question what is being done about the issues. But there should be some clear communication within the different levels of the escalation process so that it does not need to keep on going over the background. That said, I would expect all issues to be addressed by the operator (PTI), with the main reason for escalation to ICANN being that resources necessary for PTI to carry out its job are not being made available. As it stands (and as I read the document), I would worry about this draft being used as the basis for the charter review. Thanks Martin From: Elaine Pruis [mailto:elainepruis@gmail.com] Sent: 06 February 2018 16:40 To: Martin Boyle <martin.boyle.hertford@ntlworld.com>; Austin, Donna <donna.austin@team.neustar>; Drazek, Keith <kdrazek@verisign.com>; Abdalla <ceo@kenic.or.ke> Subject: Fwd: (Updated draft) Proposed RAP reviewed by ICANN Hi, Please find attached the draft CSC Remedial Action Procedures. This is after several iterations within the group and with ICANN Org. We hope to meet to finalize before the Feb 15 CSC monthly meeting. Elaine ---------- Forwarded message ---------- From: Marilia Hirano <marilia.hirano@iana.org> Date: Fri, Feb 2, 2018 at 3:10 PM Subject: (Updated draft) Proposed RAP reviewed by ICANN To: Elaine Pruis <elainepruis@gmail.com>, Allan MacGillivray <allan.macgillivray@cira.ca>, "Gannon, James-1" <james-1.gannon@novartis.com>, Byron Holland <byron.holland@cira.ca> Cc: Amy Creamer <amy.creamer@icann.org>, Naela Sarras <naela.sarras@iana.org>, Trang Nguyen <trang.nguyen@icann.org>, Samantha Eisner <Samantha.Eisner@icann.org>, Bart Boswinkel <bart.boswinkel@icann.org>, Maria Otanes <maria.otanes@icann.org> Hello RAP WG, I have attached the newest draft RAP containing the updates that we agreed on during our last call on January 23rd. We have taken all of your input into consideration, re-worded some statements, and added the formal escalation points to the PTI Board and the ICANN Board. I hope this draft meets the needs of the CSC and can be presented to the broader group in the next meeting, but we are open to more iterations if need be. Thank you and have a great weekend! Marilia
participants (2)
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Bart Boswinkel -
Martin Boyle