[Chapter-delegates] Letter to ICANN Board on the subject of "DNS" from Lynn St. Amour, President and CEO of ISOC.

[Anne Lord]

Dear Colleagues,

The email below contains the text of a letter which was sent yesterday  
to the Members of the ICANN Board of Directors from Lynn St. Amour,  
President and CEO of ISOC.

regards,
Anne
------------

April 14, 2010

To the Members of the Board of Directors
c/o Peter Dengate Thrush, Chairman
Internet Corporation for Assigned Names and Numbers
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292-6601

Dear Board Members,

On behalf of the Internet Society, I am writing to express concern  
about recent developments brought forth by ICANN pertaining to the  
security and stability of the Internet. The Internet Society shares  
the global community’s responsibility to preserve and improve  
security and stability for everyone who uses the Internet.  However,  
in our view, any effort to improve security and stability must be  
based on substantiated facts and careful planning.  During the Nairobi  
ICANN meeting, ICANN’s Chief Executive Officer claimed that the  
Internet is under attack as never before; which has raised concern  
among many, yet the facts to substantiate that statement have not yet  
been made available to the community.

While acknowledging that there are security and stability challenges  
facing the domain name infrastructure, many recognized experts in DNS  
security and operators of key Internet infrastructure are on record  
saying they do not agree that the Internet is suddenly experiencing  
dramatically greater or new types of attack, or that the DNS, or the  
Internet itself, are likely to collapse at any moment. The Internet  
Society believes it is important for the community to work together  
through established processes and institutions, each within its  
mandate, to maintain and improve security and stability.  ISOC  
believes the institutions of the security, registry and root server  
operator communities, for example, recognize the seriousness of  
attacks on Internet infrastructure; and the community is continuously  
stepping up activities (operational and development) to address them.  
The statements made in Nairobi did not say why ICANN believes those  
existing and planned activities are inadequate.

Nonetheless, in the context of its expressed concern for DNS security,  
ICANN has recently put forward two proposals to create a global DNS  
CERT capability.  No doubt, vigilance is an important part of the  
community’s efforts, as are capacity building efforts. The Internet  
Society has reviewed the ICANN proposals and, as a starting point,  
agrees that taking steps to strengthen global DNS security, stability  
and resilience is important. That said, we have strong concerns about  
how the proposals have been developed and their future path in the  
ICANN community. As with all important initiatives concerning the  
functioning of the Internet, ISOC believes it is vital to rely on the  
Internet model to get the best result. By the Internet model, we mean  
relying on open, freely accessible, multi-stakeholder, and knowledge- 
based processes for both technology and policy development.

While we agree that the security and stability of the DNS are vitally  
important, we are concerned that the current proposals do not show  
convincingly that there has been a full analysis of alternate  
approaches.  ISOC believes the proposals have been put forward  
prematurely – without the full backing of the supporting  
organizations and advisory committees in ICANN, nor with the broader  
community, including the technical community.  Specifically, there are  
many concerned with DNS security and stability from a variety of  
institutional, national and regional organizations, including from  
existing CERTs, who are not regular participants in ICANN processes  
yet who need to be engaged in any such discussion. That engagement  
should take place in the appropriate forums: often meaning that the  
relevant expertise exists outside of the ICANN process and community.

Finally, and consistent with the Internet Society’s comments in  
several past consultations by and about ICANN, we continue to be  
concerned that ICANN may be broadening out from its principle mandate  
as coordinator of the global resource that is the domain name system  
into the management of new and peripheral operational functions. More  
specifically, the two proposals to create a DNS CERT capability could  
potentially distract ICANN from its narrow technical mandate and  
distract management’s attention and resources.

For all the above reasons, ISOC strongly recommends that the  
“Proposed Strategic Initiatives for Improved DNS Security, Stability  
and Resiliency (SSR)” and the plan to create a global DNS-CERT be  
brought forward with the global Internet community to ensure that all  
relevant bodies have the opportunity to contribute to enhancing the  
security and stability of the Internet’s domain name infrastructure.

Once again, the Internet Society offers these comments in the spirit  
of continued cooperation and collaboration. We remain committed to  
supporting ICANN as we work together to carry out our public service  
responsibilities.

Sincerely yours,

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Lynn St Amour
President and Chief Executive Officer
Internet Society