[CCWG-ACCT] Your public comment re replacement of IANA provider

[Bruce Tonkin]

Hello Avri,


>>  "There need to be clear lines to keep the IRP separate from operational matters."

I think part of the approach is that IRP is a fairly heavy weight process that is designed for breaches of bylaws and articles of association, and that we should build in appeal/complaint mechanisms closer to where the issues occur.

For example, for new gTLD processes - we used review panels - but I think we also should build in appeals for the decisions of those panels - so the affected parties don't need to go to reconsideration or IRP.

If a member of the intellectual property community raises a compliance issue with the compliance team - and they feel that no action has been taken -  there should be a way to escalate this and have it dealt with.   A normal escalation path - could be to the manger, and then ultimately to the CEO.   If the CEO doesn't act then the Board etc.

If a member of the community disputes a decision regarding a travel allowance - there should be way to escalate a dispute etc.


>>  This only works if you assume that the Board does not, on its own, make policy when it decides it needs to. A decade's experience working with the Board convinces me that the Board does feel free to make policy, or to allow the staff to make policy implicitly by its actions, when it 'feels' that it is necessary.

Yes - I accept that criticism .    I am a strong believer in pushing policy decisions back to the relevant body - but it also requires some timeliness in being able to refine policies as issues evolve.

Regards,
Bruce Tonkin