Name: Shigeki Goto

Organization: Japan Network Information Center (JPNIC)

Submission ID: 78

To whom it may concern,

Please find attached response from Japan Network Information Center (JPNIC) on the ICG
Consultation on IANA Stewardship Transition Proposal.

Sincerely,

Shigeki Goto
President
Japan Network Information Center

IANA Stewardship Transition Proposal - Public Comment Form
Disclaimer: The ICG will not use the information collected for any purpose other than analyzing publiccomments. Submitters’ names, affiliations, and comments will be public.

Identifying Information* Indicates required fieldFirst Name:*Shigeki

Last Name:*GotoEmail Address:*REDACTEDCountry/Economy: Japan
Organization:

Japan Network Information Center (JPNIC)

Questions Concerning the Proposal as a Whole1)

Completeness and clarity: Is the combined proposal complete? Each of the operational
community proposals contains aspects to be completed in the future when the proposal
is implemented. Is the combined proposal specified in sufficient detail such that it can beevaluated against the NTIA criteria?

lProtocol Parameters: The community proposes to maintain the existingmechanism which is and has been functioning. We do not see any unclear
points.

lNumber resources: The essential feature of the service level agreement(SLA) to be arranged between IANA Function Operator (IFO) and RIRs andthe structure of the Review Committee are clearly defined.
While it is not directly relevant the essence of the proposal, we would
suggest the improvement of the diagram in p.10 of the draft proposal, in
which the relationship between the review mechanism of Number Community
and PTI which practically assumes IFO is unclear. Unlike the protocol
parameters, and CSC for names function, the arrow for performance review
points to ICANN. It needs to have consistency in what the arrow represents
for accurate understanding.

lDomain Names: It is clearly constructed by Post Transition IANA (PTI), IANA
Function Review Team (IFRT), and Customer Standing Committee (CSC).
Further, the standard of IANA Function Review (IFR) is consideredappropriate.

Although each of the proposals from the above three Operational Communities(OCs) have different natures based on the ways by which they have managed
Page 1 of 5the respective resources until now and have remained particulars to be defined inthe course of the implementation, those are constructed well enough as askeleton of the mechanism to secure the smooth oversight of the posttransitioned IANA function as well as those have enough details to fulfill thecriteria set by NTIA.
2)

Compatibility and interoperability: Do the operational community proposals work together
in a single proposal? Do they suggest any incompatible arrangements wherecompatibility appears to be required? Is the handling of any conflicting overlaps between
the functions resolved in a workable manner?

The proposals from Number Resources and Protocol Parameters communities
will not be inconsistent nor incompatible with the stewardship mechanism ofanother resource since they don’t provide any element which involves theresource other than each respective one. That from Domain Name community,
however, proposes PTI to perform the IFO role instead of ICANN, which is theonly part that involves the other resources. However, we conclude that
establishment of PTI does not fundamentally affect the relationship with the IFO
proposed by the Protocol Parameters and Number Resources communities.
For handling intellectual property rights (IPRs), we agree with the ICG’sassessment that the proposals from three operational communities arecompatible. This has been clearly confirmed by the CWG-Stewardship that theirposition is consistent with the combined ICG proposal on the IPR.
3)

Accountability: Do the operational community proposals together include appropriate
and properly supported independent accountability mechanisms for running the IANAfunctions? Are there any gaps in overall accountability under the single proposal?

Proposals by three OCs, because of their very straightforward structures that theorganization representing the OC who is the direct stakeholder and customer
have the stewardship, have self-evident independent accountability mechanism.
Since the IANA function directly means the aggregate of the dodger
management of the three resources, the overall accountability of the IANA
function directly means the aggregate of the accountability of those three
resources. Therefore, there is no need of additional accountability mechanism tofill the gap among three.
4)

Workability: Do the results of any tests or evaluations of workability that were included in
the operational community proposals conflict with each other or raise possible concerns
when considered in combination?

Sections P1.IV.C, P2.IV.C, P3.IV.C in the draft proposal describe the tests andevaluations of workability of new technical or operational methods. NumberResources (P2) and Protocol Parameters (P3) conclude they are workable
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because there is any new operational and technical methods for the IANA
Functions Operator. Domain Names (P1) concludes them workable as the resultof evaluation of the proposed schemes including PTI. We support theseconclusions and think that there is not any point which is inconsistent with thoseof the others. PTI may be raised as a possible concern when considered incombination, but we believe there will be no problem as we explained in 2).

Questions Concerning NTIA Criteria
5)

Do you believe the proposal supports and enhances the multistakeholder model? If yes,
please explain why. If not, please explain why and what proposal modifications youbelieve are necessary.

Yes. As shown in the section X019 1 of the draft proposal, it has the stewardshipmechanism which inherits the multistakeholder process which is existing andproven through the policy development which each OC has been working on untiltoday.
6)

Do you believe the proposal maintains the security, stability, and resiliency of the DNS?
If yes, please explain why. If not, please explain why and what proposal modifications
you believe are necessary.

Yes. The oversight mechanism ever has little impact for operational security,stability and resiliency of the DNS. The proposed stewardship mechanism
inherits the existing and proven process which each OC has applied in eachpolicy development for the standardization or resource management. It is highly
expected to maintain the security, stability and resiliency which the policy
development of each OC has brought to the Internet until today.
7)

Do you believe the proposal meets the needs and expectations of the global customers
and partners of the IANA services? If yes, please explain why. If not, please explain whyand what proposal modifications you believe are necessary. Please indicate if you are acustomer or partner of the IANA services.

Yes. The draft proposal, which has been developed by the communities
including the representative entities of OCs which are the global customers andpartners of the IANA services, self-evidently meets the needs and expectationsof them. As the respondent of this comment, JPNIC is one of National Internet
Registries which administers number resources in Japan, and a global customerof the IANA services.
1X019 original text: The ICG has concluded that the combined proposal supports and enhances themultistakeholder model because it leverages existing multistakeholder arrangements, processes, and paradigms in
defining the post-transition IANA oversight and accountability mechanisms. Each component of the proposal has
this feature.

Page 3 of 58)

Do you believe the proposal maintains the openness of the Internet? If yes, please
explain why. If not, please explain why and what proposal modifications you believe arenecessary.

Yes. The IANA function is the very foundation of the Internet infrastructure, andits stewardship mechanism hasn’t been sufficiently open for the global Internetcommunity. The draft proposal proposes to make it open to the global Internet
community with its own engagement. Therefore, the openness of the Internet will
be not only maintained but rather, it will be promoted.
9)

Do you have any concerns that the proposal is replacing NTIA's role with a governmentled or inter-governmental organization solution? If yes, please explain why and what
proposal modifications you believe are necessary. If not, please explain why.

No. Each OC, which will succeed the stewardship from NTIA, is an inclusive
community in each way. Government and government officer may of course
participate in these communities as one of the many participants, which nevermeans the community is government-led or inter-governmental organization. It isquite unlike that OCs would be as dominated by governments or intergovernmental organizations as they replace the position of NTIA, since that isagainst the multistakeholderism and not in line with the intention of the OCs.
10)

Do you believe that the implementation of the proposal will continue to uphold the NTIA
criteria in the future? If yes, please explain why. If not, please explain why and what
proposal modifications you believe are necessary.

Yes. The NTIA criteria is completely consistent with what the global Internetcommunity has aspired as the way to operate the Internet as well as how theIANA should be. With this, the global Internet community will only explore thehigher standard of the criteria and never choose the way of not meeting it. Even
if some people try to change the criteria, that will fail to get sufficient support fromthe entire OC which holds check-and-balance system within itself.

Questions Concerning ICG Report and Executive Summary11)

Do you believe the ICG report and executive summary accurately reflect all necessary
aspects of the overall proposal? If not, please explain what modifications you believe arenecessary.

Yes. We believe they accurately reflect all necessary aspect of the overall
proposal.

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General Questions
12)

Do you have any general comments for the ICG about the proposal?

JPNIC expresses a clear support on this draft proposal. As with any mechanism,
unexpected issues may be found, and we expect the global Internet community
will avoid them by periodical review and improvement of the mechanism.
As we have expressed as response to the questions, the draft proposal meets
the NTIA criteria and is perfectly consistent with what the global Internet
community has aspired as the desired, net form of stewardship of the IANA
function which is the indispensable foundation of the operation of the Internetinfrastructure. The stewardship mechanisms of three resources, which were
presented with a high level of compatibility to the others, are highly expected tofunction individually and collectively in a consistent manner, and to complete thecoordination of the details with no problem.
ICG’s call for proposal to each OC at the beginning of the consideration to leave
the drafting of the proposal for respective resource offered unrepeatable
opportunity for every member of OC, which has been developing themanagement policy of the respective resource and been proven its effectiveness,to consider the future shape of the stewardship of IANA function as one’s own
issue. We are convinced, the fact that the OCs have come back with very
reasonable proposals both individually and associated with others means that theentire Internet Community has proved its effectiveness for self-governance evenin this occasion of a dramatic change.
We congratulate all those who were involved and engaged in the development of
this proposal in ICG and all OCs for this outcome.

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