Subject: [Iasa20] Comment on RFC2031-bis

From: "Livingood, Jason" <[email-masked]>
Date: Wed, 28 Nov 2018 17:49:47 +0000

One of the RFCs the WG identified some months ago was RFC 2013 “IETF-ISOC Relationship” – see https://tools.ietf.org/html/rfc2031. As a result of IASA 2, we needed to update this and Gonzalo Camarillo graciously agreed to work with me to do so, given his unique experience with ISOC and the IETF. This draft is now posted at https://datatracker.ietf.org/doc/draft-ietf-iasa2-rfc2031bis/ and WG feedback on the contents are solicited.

Thanks in advance!
Jason

---

From: Brian E Carpenter <[email-masked]>
Date: Thu, 29 Nov 2018 08:26:56 +1300

Hi,

Thanks for this work. Two small comments:

1. The IAB Charter (RFC2850, BCP39) says this:

   The IAB acts as a source of advice and guidance to the Board of
   Trustees and Officers of the Internet Society concerning technical,
   architectural, procedural, and (where appropriate) policy matters...

It would be reasonable to mention this role in Section 5.

2. I always felt that the most important thing ISOC did for me
personally was to provide liability insurance for IETF "officials".
That will now presumably be arranged by the LLC; the change should
be noted (Section 7?).

Regards
   Brian

On 2018-11-29 06:49, Livingood, Jason wrote:
> _______________________________________________
> iasa20 mailing list
> [email-masked]
> https://www.ietf.org/mailman/listinfo/iasa20
>

---

From: "John Levine" <[email-masked]>
Date: 28 Nov 2018 20:18:24 -0500

In article <[email-masked]> you write:
>-=-=-=-=-=-
 WG feedback on the contents are solicited.

Generally it seems pretty good, but since you asked, ...

There's a bunch of stuff in 2031 that isn't in the draft, e.g., the Main
Boundary condition section on pp. 2-3.  Is the idea that the LLC provides
a bright line so we don't have to worry about the other stuff?

General note: wherever you say etc. or "and so on", I'd suggest seeing if you
can pin down what it was you left out.  

beginning of sec 6, suggest rewriting as

The IETF LLC was created as a subsidiary of ISOC.  For tax purposes it
is treated as part of ISOC, but it is managed separately.  ISOC operates
 ... 

next para:

The IETF LLC provides IETF with a separate legal existence.  The IETF
LLC structure now covers ...

and change the last line with etc. to

series and RFC editor, and all of the IETF's other business operations.

at end of the last para about the trust

The creation of the LLC has changed the way that the Trust's trustees
are selected, but did not change the purpose of operation of the Trust.

R's,
John

---

From: Gonzalo Camarillo <[email-masked]>
Date: Thu, 29 Nov 2018 11:13:22 +0000

Hi Brian,

thanks for your comments. Answers inline:

> It would be reasonable to mention this role in Section 5.

I had planned to write something about it, but reading the draft, I
clearly forgot! Thanks for catching that. I have added the following
paragraph to Section 5. What do you think?

  The charter of the IAB (Internet Architecture Board) <xref
  target="RFC2850"/> states that "the IAB acts as a source of advice
  and guidance to the Board of Trustees and Officers of the Internet
  Society concerning technical, architectural, procedural, and (where
  appropriate) policy matters pertaining to the Internet and its
  enabling technologies". This connection between the IAB and ISOC
  ensures that ISOC's proposals in the policy area are based on a
  sound understanding of the relevant technologies and
  architectures. ISOC's strong connection to the Internet technical
  community has always been one of its main strengths.

> That will now presumably be arranged by the LLC; the change should

We have avoided providing a comprehensive list of functions that have
been or are to be transferred from ISOC to the IETF LLC. Nevertheless,
we sure can mention a few examples of such functions if they are
especially important. Section 6 already includes the following text:

  This IETF LLC structure now covers the IETF standards and IETF
  standards process, all IETF officers (IAB, IESG, Nomcom, and WG
  chairs), IETF employees and contractors, the RFC series and RFC
  editor, etc.

Do we need to say more about that? If so, can you propose text (e.g.,
a sentence)? Thanks!

Cheers,

Gonzalo

---

From: Gonzalo Camarillo <[email-masked]>
Date: Thu, 29 Nov 2018 11:45:18 +0000

Hi John,

thanks for the additional comments. Answers inline:

> a bright line so we don't have to worry about the other stuff?

I delete that text because I do not think it is relevant to this
document. For example, talking about subgroups with an official role in
the standards process is up to the IETF to decide, independently from
ISOC, as the rest of the document clearly states. In any case, if there
is any particular piece of information that has been deleted and you
think should be rescued, please let me me know.

> can pin down what it was you left out.  

The previous sentence to that one includes a reference to the full
operating agreement. The sentence in question only provides a few
notable examples of activities that fall under the scope of the IETF
LLC. I have edited the sentence to make it clearer.

OLD:

  The IETF LLC will be responsible for creating and managing an annual
  operating budget for the IETF, for fund raising, for maintaining a
  bank account, and so on.

NEW:

  In particular, among other things, the IETF LLC will be responsible
  for creating and managing an annual operating budget for the IETF,
  for fund raising, and for maintaining a bank account.

Feel free to suggest an alternative wording, or any specific
responsibility of the IETF LLC you would like to see listed here.

> is treated as part of ISOC, but it is managed separately.  ISOC operates

I have changed the following:

OLD:

  The IETF LLC was organized as a "disregarded entity" of ISOC. This
  means it operates as a branch or division of ISOC for tax purposes.

NEW:

  The IETF LLC was created as a subsidiary (i.e., a "disregarded
  entity") of ISOC.  For tax purposes it is treated as part of ISOC,
  but it is managed separately.

> LLC structure now covers ...

Done.

> series and RFC editor, and all of the IETF's other business operations.

Done.

> are selected, but did not change the purpose of operation of the Trust.

Done.

You can see our working copy of the draft at:
https://github.com/IASA2/RFC-2031-bis/blob/master/draft-ietf-iasa2-rfc2031bis.xml

Cheers,

Gonzalo

---

From: "John R Levine" <[email-masked]>
Date: 29 Nov 2018 11:09:05 -0500

> responsibility of the IETF LLC you would like to see listed here.

... for negotiating, signing, and overseeing contracts, for fund raising, 
and for maintaining a bank account.

>  but it is managed separately.

That's not really right.  It's a subsidiary because ISOC owns it, but it's 
a disregarded entity because of an obscure bit of US tax law.  It has a 
technical meaning which isn't the plain meaning, because it's only 
disregarded for some tax purposes, not for contracts and lawsuits and 
everything else.  From the length of this explanation you can see why I'd 
rather avoid the rathole.

Regards,
John Levine, [email-masked], Taughannock Networks, Trumansburg NY
Please consider the environment before reading this e-mail. https://jl.ly

---

From: Brian E Carpenter <[email-masked]>
Date: Fri, 30 Nov 2018 09:05:24 +1300

>   community has always been one of its main strengths.

Yes, good.

> Do we need to say more about that? If so, can you propose text (e.g.,

Well, it may just be me, but I was very shocked when I first joined
the IAB and discovered that we had no liability insurance at a time
when standards related litigation was on the increase. For me
the ISOC insurance cover seemed like a very big deal, when it was
extended to cover IAB, IESG and WG Chairs in 1995, although as
far as I know it's never been needed.

I suggest a friendly amendment to your proposal in response

>   for fund raising, and for maintaining a bank account.

NEW NEW:

   In particular, among other things, the IETF LLC will be responsible
   for creating and managing an annual operating budget for the IETF,
   for fund raising, for maintaining a bank account and for liability
   insurance.

Regards
    Brian

---

From: "John Levine" <[email-masked]>
Date: 29 Nov 2018 16:10:58 -0500

>   for fund raising, for maintaining a bank account and for liability

Looks OK to me.

R's,
John

---

From: Bob Hinden <[email-masked]>
Date: Thu, 29 Nov 2018 13:11:38 -0800

> On Nov 29, 2018, at 1:10 PM, John Levine <[email-masked]> wrote:
> 

+1

Bob

---

From: Abdussalam Baryun <[email-masked]>
Date: Fri, 30 Nov 2018 00:57:03 +0200

Hi Jason,

I suggest that section 3 to be before section 2, or you may put the text of
section 3 into introduction (because, IMO, it is not clear or does not
clarify the relationship, the text makes confusion in my reading).

while the draft mentions that ietf LLC is branch of ISOC then it may
mention that the LLC management is appointed by IETF management (maybe
something added in section 5).

section 7>

Under the terms of the Operating Agreement between ISOC and the IETF,

ISOC has agreed to provide some funding support for the IETF (ISOC

has historically provided the IETF with significant financial

support).

AB> funding is not finance, why is the above mentioned in section 7? I
think it is historical or not necessary as relationship or can be in
separate section of funding. So historical should be in section 1 only.
Suggest delete or put into section-1.

Best Regards

AB

On Wed, Nov 28, 2018 at 7:50 PM Livingood, Jason <
[email-masked]> wrote:

> One of the RFCs the WG identified some months ago was RFC 2013 “IETF-ISOC
> Relationship” – see https://tools.ietf.org/html/rfc2031. As a result of
> IASA 2, we needed to update this and Gonzalo Camarillo graciously agreed to
> work with me to do so, given his unique experience with ISOC and the IETF.
> This draft is now posted at
> https://datatracker.ietf.org/doc/draft-ietf-iasa2-rfc2031bis/ and WG
> feedback on the contents are solicited.
>
>
>
> Thanks in advance!
> Jason

---

From: Abdussalam Baryun <[email-masked]>
Date: Fri, 30 Nov 2018 09:21:48 +0200

Hi Jason,

some other points;

IMHO, The IETF LLC agreement needs to be referenced in the reference
section, because it is the most important document of such new relationship.

while reading the LLC agreement there is some funding agreement with some
relationship of managing the fund-budget, this I think needs to be at least
mentioned in section 7.

section 6> legal relationship,

AB> Regarding Legal relationship, I suggest all agreements with ISOC should
be referred to within this section.

AB> suggest to make the relationship clear in section 7, not Finance and
Administrative jointly, so I suggest separate them,

section-7: Finance Relationship
add new-section: Administrative relationship,

Regarding the title, I suggest to delete the word .....updated......because
all relationships are updated so why mentioning. The word updated in IETF
MAY mean addition not obsolete previous relationship, but this draft does
obsolete the previous relationship RFC2031. This draft is NOT update
document.

BEst Regards
AB

On Fri, Nov 30, 2018 at 12:57 AM Abdussalam Baryun <
[email-masked]> wrote:

> Hi Jason,
>
>
> I suggest that section 3 to be before section 2, or you may put the text
> of section 3 into introduction (because, IMO, it is not clear or does not

---

From: Gonzalo Camarillo <[email-masked]>
Date: Fri, 30 Nov 2018 08:27:38 +0000

Hi Brian,

taking into account both your and John's latest comments, the
resulting text looks like this:

  In particular, among other things, the IETF LLC will be responsible
  for creating and managing an annual operating budget for the IETF;
  for negotiating, signing, and overseeing contracts; for fund
  raising; for maintaining a bank account; and for liability
  insurance.

Cheers,

Gonzalo

---

From: Gonzalo Camarillo <[email-masked]>
Date: Fri, 30 Nov 2018 08:32:24 +0000

Hi John,

taking into account both your and Brian's latest comments, the
resulting text looks like this:

With respect to your other comment, I have removed the two
instances of "disregarded entity" in the text and replaced them with the
term "subsidiary" instead.

Cheers,

Gonzalo

On 29-Nov-18 18:09, John R Levine wrote:
>> NEW:
>> 
>> In particular, among other things, the IETF LLC will be
>> responsible for creating and managing an annual operating budget
>> for the IETF, for fund raising, and for maintaining a bank
>> account.
>> 
> ... for negotiating, signing, and overseeing contracts, for fund 
> raising, and for maintaining a bank account.
> 
>> NEW:
>> 
> That's not really right.  It's a subsidiary because ISOC owns it,
> but it's a disregarded entity because of an obscure bit of US tax
> law.  It has a technical meaning which isn't the plain meaning,
> because it's only disregarded for some tax purposes, not for
> contracts and lawsuits and everything else.  From the length of this
> explanation you can see why I'd rather avoid the rathole.
> 
> Regards, John Levine, [email-masked], Taughannock Networks,
> Trumansburg NY Please consider the environment before reading this
> e-mail. https://jl.ly

---

From: Gonzalo Camarillo <[email-masked]>
Date: Fri, 30 Nov 2018 08:44:57 +0000

Hi AB,

On 30-Nov-18 00:57, Abdussalam Baryun wrote:
> of section 3 into introduction (because, IMO, it is not clear or does
> not clarify the relationship, the text makes confusion in my reading).

I agree this change will improve the flow of the document. I have
swapped both sections.

> something added in section 5).

The last paragraph of Section 7 already addresses that. Also, Section 5
is about the IETF's role in ISOC, not about the IETF's role in managing
the IETF.

> Suggest delete or put into section-1.

Those are two short sentences that are clearly related to the financial
situation of the IETF. I think it is OK to have them in that section.

Cheers,

Gonzalo

> 
> 
> Best Regards
> 
> AB
> 
> 
> 
> On Wed, Nov 28, 2018 at 7:50 PM Livingood, Jason
> <[email-masked] <mailto:[email-masked]>> wrote:
> 
>     One of the RFCs the WG identified some months ago was RFC 2013
>     “IETF-ISOC Relationship” – see https://tools.ietf.org/html/rfc2031.
>     As a result of IASA 2, we needed to update this and Gonzalo
>     Camarillo graciously agreed to work with me to do so, given his
>     unique experience with ISOC and the IETF. This draft is now posted
>     at https://datatracker.ietf.org/doc/draft-ietf-iasa2-rfc2031bis/ and
>     WG feedback on the contents are solicited.____
> 
>     __ __
> 
>     Thanks in advance!
>     Jason____
> 
>     [email-masked] <mailto:[email-masked]>

---

From: Abdussalam Baryun <[email-masked]>
Date: Fri, 30 Nov 2018 10:46:08 +0200

Hi Gonzalo,

> term "subsidiary" instead.

why removed while I did not see the discussion referred to that, or I did
not see why you removed that (reason please)

Please advise

AB

---

From: Abdussalam Baryun <[email-masked]>
Date: Fri, 30 Nov 2018 10:51:03 +0200

> not see why you removed that (reason please)

sorry ok, found that discussion thanks,

Best Regards
AB

---

From: Abdussalam Baryun <[email-masked]>
Date: Fri, 30 Nov 2018 10:56:34 +0200

Hi John,

On Thu, Nov 29, 2018 at 6:09 PM John R Levine <[email-masked]> wrote:

> .... for negotiating, signing, and overseeing contracts, for fund raising,

The subsidiary means that it is owned and controlled by ISOC but that is
not true, it is not controlled nor managed by ISOC. I think better not
mentioned subsidiary, or needs to be defined in this draft.

AB

---

From: Gonzalo Camarillo <[email-masked]>
Date: Fri, 30 Nov 2018 09:07:47 +0000

Hi AB,

thanks for these additional comments. Answers inline:

> section, because it is the most important document of such new relationship.

Yes, good point. We had indeed planned to do that and was on our TODO
list. I have added the reference now.

> while reading the LLC agreement there is some funding agreement with
> some relationship of managing the fund-budget, this I think needs to be
> at least mentioned in section 7.
> 
> 
> AB> Regarding Legal relationship, I suggest all agreements with ISOC
> should be referred to within this section.
> 

I think the structure of those sections is clear enough as is.

> Regarding the title, I suggest to delete the word
> .....updated......because all relationships are updated so why
> mentioning. The word updated in IETF MAY mean addition not obsolete
> previous relationship, but this draft does obsolete the previous
> relationship RFC2031. This draft is NOT update document.

I have removed the word from the title.

You find our working copy of the draft, which includes your comments, at:
https://github.com/IASA2/RFC-2031-bis/blob/master/draft-ietf-iasa2-rfc2031bis.xml

Cheers,

Gonzalo

> 
> BEst Regards
> AB
> 
> 
> On Fri, Nov 30, 2018 at 12:57 AM Abdussalam Baryun
> <[email-masked] <mailto:[email-masked]>> wrote:
> 
>     Hi Jason,
> 
> 
>     I suggest that section 3 to be before section 2, or you may put the
>     text of section 3 into introduction (because, IMO, it is not clear
>     or does not clarify the relationship, the text makes confusion in my
>     reading).
> 
>     mention that the LLC management is appointed by IETF management
>     (maybe something added in section 5).
> 
> 
>     section 7>
> 
>     AB> funding is not finance, why is the above mentioned in section 7?
>     I think it is historical or not necessary as relationship or can be
>     in separate section of funding. So historical should be in section 1
>     only. Suggest delete or put into section-1.
> 
> 
>     Best Regards
> 
>     AB
> 
> 
> 
>         “IETF-ISOC Relationship” – see
>         https://tools.ietf.org/html/rfc2031. As a result of IASA 2, we
>         needed to update this and Gonzalo Camarillo graciously agreed to
>         work with me to do so, given his unique experience with ISOC and
>         the IETF. This draft is now posted at
>         https://datatracker.ietf.org/doc/draft-ietf-iasa2-rfc2031bis/
>         and WG feedback on the contents are solicited.____
> 
>         __ __
> 
>         Thanks in advance!
>         Jason____
>

---

From: Joseph Lorenzo Hall <[email-masked]>
Date: Fri, 30 Nov 2018 06:52:00 -0500

> mentioned subsidiary, or needs to be defined in this draft.

I think you're mistaken; it is owned and managed by ISOC, but with a lot of
careful attention to making sure we can run IETF in a more independent
manner than in the past.
-- 
Joseph Lorenzo Hall
Chief Technologist, Center for Democracy & Technology [https://www.cdt.org]
1401 K ST NW STE 200, Washington DC 20005-3497
e: [email-masked], p: 202.407.8825, pgp: https://josephhall.org/gpg-key
Fingerprint: 3CA2 8D7B 9F6D DBD3 4B10  1607 5F86 6987 40A9 A871

---

From: "John R Levine" <[email-masked]>
Date: 30 Nov 2018 08:59:35 -0500

> mentioned subsidiary, or needs to be defined in this draft.

Joe is correct.  The LLC is ultimately controlled by ISOC even though the 
structure makes the day to day management separate.

This was discussed at great length on the iasa20 mailing list.  Please see 
the archives for more details.

Regards,

---

From: Abdussalam Baryun <[email-masked]>
Date: Fri, 30 Nov 2018 18:36:22 +0200

On Fri, Nov 30, 2018 at 1:52 PM Joseph Lorenzo Hall <[email-masked]> wrote:

>
>
> On Fri, Nov 30, 2018 at 03:57 Abdussalam Baryun <
> I think you're mistaken; it is owned and managed by ISOC, but with a lot
> of careful attention to making sure we can run IETF in a more independent
> manner than in the past.
>

It mentions in the LLC agreement  section of management 5, that the board
manages the company, and then in the agreement mentions the board directors
are mostly IETF members. Usually subsidiaries are more than 50% of board.
However, if it is not controlled by IETF then could we make it clear text
showing the control of the LLC in this relationship draft.

AB

---

From: Abdussalam Baryun <[email-masked]>
Date: Fri, 30 Nov 2018 18:48:05 +0200

> the archives for more details.

ok, if discussed and agreed by the WG, then we need the authors to
clarify the management of LLC in this IETF-ISOC relationship draft, and how
managed separate and in the same time ultimately controlled by ISOC. IMHO
the LLC agreement does not mention the total control by ISOC.

AB

---

From: Joseph Lorenzo Hall <[email-masked]>
Date: Fri, 30 Nov 2018 11:56:01 -0500

> the LLC agreement does not mention the total control by ISOC.

That's the entire point of the LLC agreement. It says that IETF shall issue
one controlling membership and that has to be issued to ISOC. While ISOC
can do what it wants there are terms in the agreement, see Section 12  and
13, that further specify under what circumstances the IETF could transfer
that membership to another entity or ISOC could dissolve the IETF LLC
(short version: it likely requires consent of the IETF LLC).

It seem like you want text added to this part of the document:

The IETF LLC was created as a subsidiary of ISOC.  For tax purposes it
is treated as part of ISOC, but it is managed separately. ISOC
operates as a U.S. 501(c)(3) not-for-profit organization, and was
founded to support and promote the development of the Internet as a
global technical infrastructure, a resource to enrich people's lives,
and a force for good in society. The Limited Liability Company
Agreement of IETF Administration LLC, dated August 27 2018, is the
Operating Agreement <xref target="OpAgreement"/> that governs the
relationship between the IETF LLC and ISOC.

Would something along the lines of the following suffice:

"The IETF LLC was created as a subsidiary of ISOC, meaning that ISOC
retains ultimate control over the IETF LLC, but under an agreement that
carefully cabins the relationship outlined in this document."

best, Joe

---

From: Abdussalam Baryun <[email-masked]>
Date: Fri, 30 Nov 2018 19:07:28 +0200

Hi Joe,

On Fri, Nov 30, 2018 at 6:56 PM Joseph Lorenzo Hall <[email-masked]> wrote:

> That's the entire point of the LLC agreement. It says that IETF shall
> issue one controlling membership and that has to be issued to ISOC. While
> ISOC can do what it wants there are terms in the agreement, see Section 12
> and 13, that further specify under what circumstances the IETF could
> transfer that membership to another entity or ISOC could dissolve the IETF
> LLC (short version: it likely requires consent of the IETF LLC).
>

Yes I think that is more clear for me, thanks,

AB

---

From: "John R Levine" <[email-masked]>
Date: 30 Nov 2018 12:36:18 -0500

> the LLC agreement does not mention the total control by ISOC.

I don't think it would be useful to try and paraphrase LLC law or the 
contents of the LLC agreement in an RFC.  The agreement is posted on the 
LLC web site (or will be shortly) and anyone who cares can read it.

Sections 11b and 11c of the LLC agreement make it quite clear what ISOC's 
control is.

Regards,

---

From: "John Levine" <[email-masked]>
Date: 30 Nov 2018 18:04:29 -0000

In article <[email-masked]>,
>carefully cabins the relationship outlined in this document."

I still don't think that trying to paraphrase the LLC agreement and LLC law
is productive.

How about this:

"The IETF LLC is governed by an operating agreement between ISOC and
the LLC that is published on the LLC's web site at x."

R's,
John
-- 
Regards,
John Levine, [email-masked], Primary Perpetrator of "The Internet for Dummies",
Please consider the environment before reading this e-mail. https://jl.ly

---

From: Joseph Lorenzo Hall <[email-masked]>
Date: Fri, 30 Nov 2018 13:12:31 -0500

On Fri, Nov 30, 2018 at 1:04 PM John Levine <[email-masked]> wrote:

> In article <
> [email-masked]>,

Totally understand the risk in paraphrasing, WFM

---

From: Brian E Carpenter <[email-masked]>
Date: Sat, 1 Dec 2018 08:11:57 +1300

wfm, thanks

   Brian

---

From: Alissa Cooper <[email-masked]>
Date: Fri, 30 Nov 2018 15:48:51 -0500

> On Nov 30, 2018, at 1:04 PM, John Levine <[email-masked]> wrote:
> 

I think it may be worth considering that this is true for much of sections 2, 6, and 7. I fear that any discrepancy between this text and the LLC agreement may be re-interpreted by future readers to mean something that isn’t implied by this WG at this time. Re-using exact text from the LLC agreement seems safer.

Which leads me to a broader question: what is the goal of this document and who is its intended audience? It addresses only some aspects of the IETF-ISOC relationship and not others. For example, there are a number of ISOC programs related to the IETF and IETF standards and a number of ISOC staff who currently provide support services to the IETF in various capacities, none of which are mentioned. Some aspects of these arrangements are fluid, so I can see why it may be hard to characterize them at a high level. But if this document is meant to capture the relationship in its totality, there seem to be ommissions. OTOH, leaving these out would make sense if the document were limited to administrative, legal, and financial matters, but it isn’t.

Alissa

---

From: "John R Levine" <[email-masked]>
Date: 30 Nov 2018 15:54:27 -0500

> I think it may be worth considering that this is true for much of sections 2, 6, and 7. I fear that any discrepancy between this text and the LLC agreement may be re-interpreted by future readers t…

Well, you can disclaim that away ("this document is intended as a summary 
of the agreement, but only the agreement is authoritative") but I agree
with you that it's not clear what the audience and goal of this document 
is.

Regards,

---

From: Brian E Carpenter <[email-masked]>
Date: Sat, 1 Dec 2018 15:05:22 +1300

> with you that it's not clear what the audience and goal of this document 

Historically, there was considerable concern in the community back in the early/mid 1990s about the impact of ISOC on the IETF's independence, and my recollection is that RFC2031 was intended to allay those concerns.

That being so, it's now factually inaccurate, so IMHO we have a choice between replacing it or simply obsoleting it. I don't think we really need to expand its scope, but maybe some emphasis on the independence aspect would be helpful, to indicate why the document exists.

   Brian