[Chapter-delegates] ISOC Draft Response to the US Department of Commerce IANA Further Notice of Inquiry

[Christopher Wilkinson]

Dear Markus:

Thankyou. Your explanations are fully understandable and well noted. I  
consider that the final version of our response to NTIA is very  
convincing and valid from all points of view.

The new footnote (p2) is very helpful.

Best regards,

Christopher.




On 29 Jul 2011, at 20:43, Markus Kummer wrote:

> Dear Christopher,
>
> A belated thanks you for the questions you raised. By now you have  
> receive our final text. Based on your input we have made it more  
> explicit in some areas and hope that the final version meets your  
> concerns.
>
> Please find below some more detailed answers to your comments (which  
> were echoed by Veni). Also attached is the version of the response  
> as submitted to the NTIA and as it will be posted on the ISOC website.
>
>> I have three specific comments:
>>
>> 1.	The draft ISOC response is silent as to whether ICANN should  
>> continue to be the contractor. Although this may be advisable for  
>> formal reasons, I think it should be understood that it would be  
>> materially impossible for a different contractor to fulfill the  
>> requirements regarding multistakeholder process and the development  
>> of associated policies. I have addressed this aspect in my earlier  
>> submission to NTIA.
>
> In our submission we reaffirm  the points expressed in our response  
> to the NOI. We made it clear then that we support ICANN as the  
> continuing operator of the joint IANA function. We wrote:  "In  
> conclusion, the Internet Society offers the following statement from  
> its Board of Trustees, resulting from a recent discussion of how the  
> IANA functions are currently being handled: "ISOC supports ICANN as  
> the continuing operator of the joint IANA functions, and believes  
> that the current stakeholder communities should remain in charge of  
> the evolution of their relevant functions. For the IP address space,  
> that is the Regional Internet Registries; for the protocol  
> parameters, that is the Internet Architecture Board; for domain name  
> evolution, that is the consultative committees and current  
> operators." This remains valid.
>>
>> 2.	I am not convinced that it is necessary or helpful to emphasise  
>> the "equal importance" of the separate IANA functions, providing  
>> that they are kept together in a single entity. In my experience,  
>> the overwhelming attention of the affected stakeholders indeed  
>> relates to the DNS component.
>
> While it is true that the overwhelming attention relates to the DNS  
> component, we nevertheless hold the view that the other two  
> functions, as outlined in the answer to your first question, are of  
> equal importance to the good functioning of the Internet and we  
> align ourselves with the IAB response. We take it that the first  
> version of our response may not have been clear enough in this  
> regards and hope that the final version of our makes this more  
> explicit.
>>
>> 3.	I am rather troubled by ambiguities arising from expressions  
>> such as "materially affected parties", "non-materially affected  
>> stakeholders", "materially concerned parties" etc. Who decides  
>> which is who and who is which?
>
> The first draft may not have been clear enough. We have added some  
> wording to clarify our thinking and, again, we endorse the IAB  
> response. The ‘materially affected parties are those that perform  
> each of the three IANA functions; in our view, they are directly  
> affected by the IANA contract, although thy are not bound by the  
> contract.
>
>>
>> 	Also, I would not "single out" the Internet technical community  
>> (however defined) in this context because that would be unnecessary  
>> in a multistakeholder process, and would invite other communities  
>> to require the same privilege, notably the ccTLD community and the  
>> governments. (Indeed, the GAC early addressed the relationships  
>> between IANA, ccTLDs and their governments, and presumably  
>> continues to take and interest in this area.)
>>
>> I trust that you and your colleagues will find these comments  
>> useful and will be able to take them into account.
>
> This relates to the performance of the IANA functions. There are  
> three materially affected parties: the NRO for the IP address space,  
> the IAB for the protocol parameters and ICANN for the DNS.  The  
> ccTLD community and the GAC are part of the ICANN process.
>
> Best regards
> Markus
>
>
> <Internet Society Response to the NTIA's FNOI on the IANA Functions  
> (July 2011)(1).pdf>