[discuss] Fwd: InternetNZ response to call for comments - IANA transition

Jordan Carter jordan at internetnz.net.nz
Wed May 7 05:18:17 UTC 2014

Dear /1net colleagues,

Please find our comments on the IANA transfer issue below & attached.
Comments are open until 8 May, and I would encourage those interested
to make comments.

Info on what this is and how to make comments are at


---------- Forwarded message ----------
From: Jordan Carter <jordan at internetnz.net.nz>
Date: 7 May 2014 17:12
Subject: InternetNZ response to call for comments - IANA transition
To: "ianatransition at icann.org" <ianatransition at icann.org>


Please find attached and copied below in plain text, comments from
InternetNZ on the IANA transition.


Response to ICANN call for comments on IANA transition

7 May 2014

This paper[1] sets out InternetNZ's response to ICANN's call[2] for
comments on the process, mechanisms, principles and scope of work to
transition NTIA's stewardship of the IANA functions to the global
multistakeholder community. Our comments are brief.

:: Overarching points ::

* It is unfortunate that two separate processes - for accountability
of ICANN broadly, and for the IANA transition - are being undertaken
separately and not in a coordinated way.

* A successful IANA transition depends on appropriate accountability
for IANA functions, but a critical method for achieving such
accountability - the structure of IANA operations - is deemed out of
scope within this IANA transition process, without any firm commitment
that it will be tackled through the ICANN accountability process.

* ICANN and the NTIA must agree - and state publicly - that without
appropriate accountability arrangements, no transition can proceed.

* We agree with and endorse the ccNSO Council's contribution[3] to
this discussion.

:: On the Scope document ::

* We agree with the calls by regional organisations (for example
APTLD) and ICANN SOs (for example the ccNSO) for the scope of the IANA
transition to include discussion of how to deal with NTIA no longer
being the party that specifies the IANA and RZM functions or contracts
for them.

* Currently the scope rules this out by ruling out matters related to
the structure of the IANA operation. It must be possible to discuss
these issues in this transition discussion, independent of broader
discussions of ICANN's accountability.

* Aside from this glaring exception, the rest of the scope document is

:: On the Process document ::


* The IAB's suggestion[4] of a smaller, light-weight coordination
group to manage the whole transition, and separate Steering Groups or
other community-relevant approaches to develop the detail within each
customer segment, has some merit - as long as there is capacity to
ensure the plans are able to be implemented together.

* The domain names element of the transition would then be managed by
a larger Steering Group composed more narrowly of relevant parties.

* There is also the concern that the same people are appearing in all
sorts of 'coordination' groups, largely as ex-officio appointments,
and we are therefore reducing the breadth of input and increasing the
already powerful influence of a few.

* Registry customers - in the case of domain names gTLD and ccTLD
operators - are affected parties and need to be represented directly
in the names Steering Group. Any group which fails to include them
will lack legitimacy. It is not appropriate to separate the concerns
of the customers of the IANA service from the concerns of the
provider/s of that service.

* Groups (SOs, ACs, customers) represented on the Steering Group must
be selected by their own communities, not by the ICANN Chair and GAC
Chair. Such representatives must be actively selected by their groups,
not appointed ex-officio.

* Staffing resources should be independent of ICANN and procured by
the Steering Group, financed by ICANN.

Process to develop the transition plan:

* There must be sufficient rounds of community engagement to allow the
right plan to be built. At a minimum this will involve engagement
rounds on:

  - The issues set - what needs to be covered by the transition plan
  - Options or approaches to deal with the issues set
  - Development of a strawman plan
  - Scenario or stress-testing the strawman
  - Development of the final plan, including implementation planning.

* This process cannot be completed before mid-2015. Rushing to meet
non-relevant deadlines (e.g. the ITU Plenipotentiary, ICANN 51 in Los
Angeles) is not appropriate.

* There must be cross-linkages with the Accountability work (announced
as this document was being finalised) to avoid incompatible
accountability approaches being developed in respect of NTIA's
stewardship of the IANA functions (which must be part of this
process), and in respect of broader ICANN accountability.

* The transition plan cannot be finalised before, and must include a
summary of, agreed changes to accountability arrangements to ensure
that the full picture is taken into account and signed off.

:: Other matters ::

* A crucial initiative for the Steering Group is to commission
independent external advice on the transition from knowledgeable
advisors on issues such as e.g. IANA governance, and to publish these
for community input. Those providing such advice must be of a calibre
and reputation that the community can be confident they are providing
truly independent advice, not affected by client pre-conceptions or
ICANN interests. Advisors for this purpose should come from both the
U.S. and from other jurisdictions.

* ICANN must carefully manage perceptions of self-dealing in
developing the transition plan through careful and appropriate use of
language, and resisting the temptation to interfere in the work of the
Steering Group.

With many thanks for your consideration,


7 May 2014

For further information contact:

Jordan Carter (InternetNZ Chief Executive) - jordan at internetnz.net.nz

Keith Davidson (InternetNZ International Director) - keith at internetnz.net.nz

Debbie Monahan (Domain Name Commissioner) - dnc at dnc.org.nz

Jay Daley (NZ Registry Services Chief Executive) - jay at nzrs.net.nz

Ellen Strickland (InternetNZ Collaboration and Community Lead) -
ellen at internetnz.net.nz


[1] Archived on our website at

[2] Available at

[3] Available at

[4] Available at

Jordan Carter

Chief Executive

04 495 2118 (office) | +64 21 442 649 (mob)
jordan at internetnz.net.nz
Skype: jordancarter

To promote the Internet's benefits and uses, and protect its potential.
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