I am planning to file a comment on Consultation on the IANA Customer Service Complaint Resolution Process

https://www.icann.org/en/news/public-comment/iana-complaint-resolution-27nov12-en.htm

Below are my first thoughts.  As this is due by 18th December I will not have time to verify this as a NCUC or a NCSG comment before submission and will therefore submit as an individual.

However, I do have enough time to gather any opinions from the NCSG- DIscuss list before I submit on the 18th.  If I change it based on consultations wit the list, I will mention that in the submission.

And, if either the NCUC, NPOC or NCSG wish to endorse the comment I send in, or wishes to add/disagree with it, they can do so as part of the reply period.  This is one handy aspect of the 2 stage process that we can use.  If last minute commenters, as I so often am, cannot get C/SG endorsement before submission, the reply period offers the C/SG the time to comment on the comment.

avri

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The complaint resolution process appears to be adequate.  Some specific comments on the document:: 


1. Re:
"
Ideally, the escalation process would be initiated by the individuals appointed by the leaders of the various organizations that the IANA functions directly serve, including the IAB, IESG, and IETF, the ccNSO, TLD managers,
"

A. Does this process not also apply to gTLDs.  If so, could the GNSO, or one of its stakeholder groups, initiate a complaint?  This may be very relevant during the upcoming period when there is a growth in the number of new gTLDs requiring IANA services.  If this is the case, perhaps a specific mention of the GNSO and its constituencies is warranted.
B. Why would a complaint from a registrant or Internet user not be appropriate if it related to a relevant IANA activity?
C. Could a complaint come from the ALAC, in regard to problems that may be suffered by the At-large users of the Internet, or from the GAC or its members related to issues related to governments?
C.  Could a complaint come from individual protocol authors or implementors who request code points that do not need to be approved by the  IETF processes before assignment.

2. Re:
"
As the final level of escalation (or at any time the requester feels this escalation procedure is not being followed or is not effective),
"

I think it would be good to bring out that fact that the Ombudsman is a step that can be taken at any point in the process, as oppose to including that fact as a parenthetical.   Consider mentioning the Ombudsman at the topic of this section as well as including it as the last step.


Specific Answer to the questions of the consultation:

The efficacy of the process should be measured and reviewed.  It is only worth fixing or replacing the process with another process if it can be shown that this process has not been effective. 

Questions that might be asked in a review:

- How many complaints have been escalated?  
- How many complaints, if any, have fallen through the cracks or exceeding a reasonable time frame? 
- What sort of complaints, if any have reached the ombudsman and on what frequency?
- To what degree are those who filed complaints satisfied with the service they received?