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Re: [apnic-talk] Isoc India Chennai comments on the application to form

Subject: Re: [apnic-talk] Isoc India Chennai comments on the application to form the NIR in India
From: "Col. R. S. Perhar"
Date: Tue, 1 Dec 2009 16:49:31 +0530
I have been seeing a number of mails on NIR for India in the recent
past.Mail from ISOC Chennai below is a fairly comprehensive mail on the
The success of NIR depends on formulation of a independent organization. The
organization has to be physically, functionally, operationally free from any
kind of lobbying and interference. The structure of the
organization,selection of office bearers, their roles and responsibilities
etc will need to be weighed against the primary concern of being a free and
Independent organization. Then and only then that organization will be truly
able to service all the stake holders in good faith and right sprit.
I am sure that the leadership in ISPAI and NIXI is taking all these factors
in view when working out the contours of the proposed organization.

Col. R. S. Perhar

-----Original Message-----
From: [email protected]
[mailto:[email protected]] On Behalf Of Sivasubramanian
Sent: Monday, November 30, 2009 9:21 PM
To: [email protected]
Cc: [email protected]
Subject: [apnic-talk] Isoc India Chennai comments on the application to form
the NIR in India


The following are comments sent to the Executive Secretary of APNIC today.
The PDF file as sent is also attached. Posted here for

Comments on the application from the National Internet Exchange of India to
form a NIR in India

The concept of National Internet Registries (as against the Regional
registries such as APNIC) has the potential danger of paving the way for a
geographically - or nationally - fragmented Internet. While the RIR have
already decided to encourage NIR's, ISOC India Chennai wishes to place on
record a general comment common to all NIR's proposed under the five RIR's:

It is theoretically possible for any National Government to 'separate'
the Internet within its borders by implementing certain policies and
practices peculiar to its English and IDN ccTLD domain space in combination
with specific policies and practices for the IP address space under its NIR.
This possibility makes it all the more important for the RIR's to ensure
that the local policies of the NIRs do not conflict in any way with regional
or global policies.

On the application from the National Internet Exchange of India to form a
NIR in India, ISOC India Chennai comments as follows:

The application to form the NIR in India is filed by the National Internet
Exchange of India (Nixi) together with the Internet Service Providers
Association of India (ISPAI) as a consortium application.
The arrangement proposed by the ISPAI is that Nixi would handle policy and
financial aspects of the NIR while the "full responsibility for execution"
will rest with the ISPAI.

Clause 3.2..2 of the NIR criteria states "NIR must be ... neutral with
respect to the Internet industry ... NIRs should not provide ISP services
... ...NIRs should not have any special corporate or contractual
relationship with any ISP within their service region."

Nixi was formed by the Department of Information Technology in association
with the Internet Service Providers Association of India.
At least 34 Internet Service Providers (ISPs), including major Class A ISPs
are part of Nixi as peering ISPs.

The majority of Directors of Nixi are elected by member ISPs. It would not
be entirely correct to assume that Nixi does not have (an
implicit) 'contractual relationship with the ISPs'. By extension, the NIR
proposed as a body jointly promoted by Nixi and ISPAI may not be free of
implied and unspoken contractual relationship with the ISPs.

While ISOC India Chennai observes that the Internet Service Providers of
India have policies and practices that are largely balanced, it objects - in
principle - to the totality of control that the NIR would offer to the ISPs.
In India in particular, the IP address space policies of the ISPs have
favored large bandwidth users with high revenue bandwidth plans. Static IP
addresses were allotted to users on bandwidth plans in excess of US $ 300 -
500 per month, while the average user was not assigned a static IP
addresses. While APNIC allots IP address blocks to ISPs at a negligible
cost, the ISPs in India have indirectly gained substantial revenues by
controlling IP address allocation to users. If the ISPAI or an
ISPAI-dominant body is conceded the role of NIR, IP address space may be
managed in such a way that even the abundant Ipv6 addresses offer indirect
revenues to the ISPs. This is part of the rationale behind our hesitation to
unconditionally support this application.

In order to ensure that the proposed application for the NIR in India meets
the provisions of Clause 3.2.2 and other clauses, APNIC may suggest that

- NIXI should confirm that the proposed NIR would adhere to Internet Core

- NIXI should assure that its operational procedures of the proposed NIR
will be non-discriminatory in any way (race, gender, religion, political
ideology, opinion)

- NIXI should make sure that the proposed NIR involves equal and meaningful
participation, not only by the Indian ISP community, but also by a true
representation of the Internet User communities. NIXI should confirm that it
intends to function following a multi-stakeholder participatory model. In
the process Nixi should gain greater independence from the Government

- NIXI should continue to support the free choice of ISPs to receive
services from the NIR or APNIC and ensure that there are no direct or
indirect pressures on any ISP in India to confine its options to address
space from the NIR. This free choice is of paramount importance for further
development of Internet in India

While ISOC India Chennai has faith in Nixi as a progressive institution and
feels that a Nixi initiative to form an NIR as broadly agreeable, it wishes
to recommend that APNIC does not rush into a decision to approve the
proposal for the NIR and commissions a study regarding the restriction of
allocation of IP addresses in India.
APNIC may have to wait until there is clear evidence that all ISPs and all
stakeholders have been duly consulted and informed on the proposal to
establish the NIR.

The most significant ISPs in India are primarily telephone companies that
have transitioned from the telecom sector. These telco/ISPs are part of
large corporate groups that have caused considerable national economic
development in the process of their own business growth; Their size and
importance places them in a position to wield considerable influence over
Internet policies, which makes it imperative to ensure that these
corporations as ISPs do not gain an even larger position in the Internet
arena that would be difficult to balance.

Sivasubramanian Muthusamy

Blog: http://isocmadras.blogspot.com
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