**Italian chapter of ISOC (Società Internet)**

**response to questions raised in the**

**NTIA Notice of Inquiry on**

**"The Continued Transition of the Technical Coordination and Management
of the Internet Domain Name and Addressing System"**

The Italian chapter of ISOC, named Società Internet has 100 individual
members and other 120 persons that participated in the discussion on the
subject, through our mailing lists. After our internal consultation, we
welcome the opportunity to give input to this process and to submit the
following responses to the questions raised. We intend to express our
positive evaluation of the initiative of NTIA to start a public
consultation on such a delicate and contentious matter; the only
critical note we raise is the late announcement and consequent short
time to respond.

Q1: The DNS White Paper articulated principles (i.e., stability;
competition; private, bottom-up coordination; and representation)
necessary for guiding the transition to private sector management of the
Internet DNS.  Are these principles still relevant?  Should additional
principles be considered in light of:  the advance in Internet
technology; the expanded global reach of the Internet; the experience
gained over the eight years since the Department of Commerce issued the
DNS White Paper; and the international dialogue, including the
discussions related to Internet governance at the United Nations World
Summit on the Information Society (WSIS)?

R1: Isoc.it is convinced that the principles expressed in the White
Paper are still valid and keep their initial relevance. In particular,
the continuous expanding of international reach of the Internet can best
be accommodated and further supported by these principles. The outcome
of the WSIS process, in our view, does not contradict the White Paper
principles. We believe that management of the DNS is best served in the
private sector and wholly endorse the view of the UN Secretary General
at the World Summit on the Information Summit: "***I believe all of you
agree that day-to-day management of the Internet must be left to
technical institutions, not least to shield it from the heat of
day-to-day politics**".*

**Q2:  The DNS White Paper articulated a number of actions that should
be taken in order for the U.S. Government to transition its Internet DNS
technical coordination and management responsibilities to the private
sector.  These actions appear in the MOU as a series of core tasks and
milestones.  Has ICANN achieved sufficient progress in its tasks, as
agreed in the MOU, for the transition to take place by September 30,
2006?**

R2: ICANN has made outstanding progress since its establishment although
further improvements may be achieved. Our overall evaluation is positive
considering the series of tasks and milestones envisaged in the MoU.
Some of those are of a general nature and are subject to subjective
judgment like the part regarding the inclusiveness of all stakeholders;
it is clear, in this respect, that the achievement is not yet completed
but is far along the established path. In the end, we do not see reasons
to delay the transition after September 2006; if this will not finally
judged as the case by the DoC, we would like to see a much lighter
substance and language in the extension of the MoU, compared to the
present one.

Q3: Are these core tasks and milestones still relevant to facilitate
this transition and meet the goals outlined in the DNS White Paper and
the U.S. Principles on the Internet's Domain Name and Addressing
System?  Should new or revised tasks/methods be considered in order for
the transition to occur?  And on what time frame and by what method
should a transition occur?

R3: We first observe that The "U.S. Principles on the Internet's Domain
Names and Addressing System" gave rise to an interpretation of
substantial discrepancy if compared with the White Paper and we concur
with that impression. We understand though that the rational in the
"U.S. Principles on the Internet's Domain Names and Addressing System"
is aiming at assuring the long term stability of the network and that,
until now, there are not different internationally agreed models that
satisfy the governments expectations to play an oversight role in the
global governance of the DNS. We think that, in order to lower the push
of some governments in the direction of a global governmental control
the Internet, the U.S. government should make a sensible step back in
supervising ICANN, as it was envisaged in the White Book. For example we
believe there is no longer reason why the DoC has to provide it's final
approval for any even small change of the root zone file. ICANN
endeavors a major confidence.

**Q4: The DNS White Paper listed several key stakeholder groups whose
meaningful participation is necessary for effective technical
coordination and management of the Internet DNS.  Are all of these
groups involved effectively in the ICANN process?  If not, how could
their involvement be improved?  Are there key stakeholder groups not
listed in the DNS White Paper, such as those with expertise in the area
of Internet security or infrastructure technologies, that could provide
valuable input into the technical coordination and management of the
Internet DNS?  If so, how could their involvement be facilitated? **

R4: ICANN has been careful until now not to go beyond its core business.
Since there are expectations on ICANN to enter into areas that are not
strictly related with DNS, although in some way related to it, and the
Internet community has growing expectations on ICANN (that is considered
a good model for organizing the private sector in satisfying the needs
of the community in the governance of the Internet), we should be
careful here to introduce (or not) new stakeholders that will enlarge
the spectrum of activities of ICANN. The funding model of ICANN should
be revised in order to foresee funding contributions targeted to
functions that are of interest of the new stakeholders. We are referring
here to security problems that could be of interest of the ISP sector
(not only those involved in DNS), to Internationalized Domain Names and
problems connected to contents, to migration to Ipv6, etc.

Q5: The DNS White Paper listed principles and mechanisms for technical
coordination and management of the Internet DNS to encourage meaningful
participation and representation of key stakeholders.  ICANN, in
conjunction with many of these key stakeholders, has created various
supporting organizations and committees to facilitate stakeholder
participation in ICANN processes.  Is participation in these
organizations meeting the needs of key stakeholders and the Internet
community?  Are there ways to improve or expand participation in these
organizations and committees? 

R5: If we look at the three existing supporting organizations, it is
evident that the ccNSO is the one that is still less inclusive as a
consequence of some difficulties of tuning the formal relations of ICANN
with the country code registries. Improvements are on the way but the
process is going slowly. To date, the ccNSO has not attracted many
European ccTLDs and consequently cannot yet be seen as a means of
inclusive ccTLD participation, although they are numerous and vocal in
ICANN meetings. We note that steps have been taken to amend the ICANN
bylaws with respect to the ccNSO.

For what regards advisory committees, we note that the process to a full
participation of registrants and end users through the At Large Advisory
Committee has not been completed yet. This is due to the inherent
complexity of the task, but also to the lack of incentives, and in
particular of direct influence over final decisions. Given the original
reasons given in the White Paper -- where a significant representation
of users at the voting Board level was foreseen as a balancing element
to preserve the general public interest -- we think that ICANN should be
invited to find ways to restore in part such representation.

***Q6: What methods and/or processes should be considered to encourage
greater efficiency and responsiveness to governments and ccTLD managers
in processing root management requests to address public policy and
sovereignty concerns?  Please keep in mind the need to preserve the
security and stability of the Internet DNS and the goal of
decision-making at the local level.  Are there new technology tools
available that could improve this process, such as automation of request
processing?***

R6: ItIt is of utmost importance for the stability of the DNS, and
ultimately the Internet, that the root database is managed as a
technical function; this is absolutely necessary for the country codes.
We advance the request that the present procedure concerning
modifications of the zone file records regarding ccTLDs skips the final
step of approval by DoC; ICANN should be given the credit to interpret
independently its technical role. This is the only sound way, to our
opinion, to respect paragraph 63 of the Tunis agenda (***Countries
should not be involved in decisions regarding another country's
country-code Top-Level Domain (ccTLD). Their legitimate interests, as
expressed and defined by each country, in diverse ways, regarding
decisions affecting their ccTLDs, need to be respected, upheld and
addressed via a flexible and improved framework and mechanisms***.) and
the paragraph 2 of the "U.S. Principles on the Internet's Domain Names
and Addressing System" that reads: "***The United States recognizes that
governments have legitimate public policy and sovereignty concerns with
respect to the management of their ccTLD. As such, the United States is
committed to working with the international community to address these
concerns, bearing in mind the fundamental need to ensure stability and
security of the Internet's DNS."***

In light of this, ICANN should respond without delay to notifications of
changes to the information in the IANA database submitted by registry
managers provided they pass the necessary technical checks. Such checks
must follow a clear and transparent process according to objective,
non-political and publicly available criteria.

***Q7: Many public and private organizations have various roles and
responsibilities related to the Internet DNS, and more broadly, to
Internet governance.  How can information exchange, collaboration and
enhanced cooperation among these organizations be achieved as called for
by the WSIS?***

R7: Isoc.it looks to the Internet Governance Forum to provide the arena
for global discussion and common action on the issues highlighted by the
WSIS regarding the broad definition of Internet governance. We do not
believe that any additional bodies are required. IGF will have positive
results if all the organizations involved, both of a private and
intergovernmental nature, will take the commitment, in the near future,
to be more synergic than they are at present. The Internet community
requires that strongly; this is the message to be passed in Athens.

## Società Internet -- Italian chapter of ISOC

The President

07 July 2006