Dears,

After a review of the “Governance Document for the Recognition,
Maintenance, and Derecognition of Regional Internet Registries” draft, I
would like to submit the following feedback:



*1. Insufficient Clarity Regarding Regional Continuity After Derecognition*

*Observation:*
The draft outlines the procedures for derecognizing an RIR but *does not
provide clarity* on how continuity of Internet number resource management
will be maintained in the affected region after derecognition.

*Impact:*
The absence of a predefined transitional or fallback mechanism poses
operational risks for resource holders in the affected region and may
jeopardize Internet infrastructure stability at a regional level.

*Recommendation:*
Including a clear provision specifying:

   - An obligation to guarantee service continuity for affected resource
   holders,
   - A framework for temporary stewardship or reassignment of
   responsibilities to an interim or existing RIR,
   - A stakeholder consultation process to guide regional transition
   planning.

This addition would align with the draft's stated goal of safeguarding the
reliability and neutrality of the Internet number registry system.



*2. Concerns About the Requirement for Unanimous RIR Support for New RIR
Recognition*

*Observation:*
Section 2.3(c) implies that *unanimous support* from all existing RIRs is
necessary before forwarding a Candidate RIR proposal to ICANN for final
approval.

*Impact:*
Requiring unanimous agreement effectively grants any single RIR the power
to veto the recognition of a new RIR, regardless of demonstrated regional
need or readiness.
This could inhibit the natural evolution of the registry system,
particularly in underserved or emerging regions that meet the technical and
governance standards.

*Recommendation:*
Revising the requirement to allow for a *qualified majority* (e.g., three
out of five RIRs) within the NRO Executive Council for forwarding a
recognition proposal to ICANN.
This change would uphold the principles of collaborative governance without
unduly blocking legitimate initiatives.



BR,

Abdulrahman
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