Name: Peter Van Roste

Organization: CENTR

Submission ID: 83

Please find attached the CENTR comment on the IST proposal.
Thank you for confirming receipt.

Best Regards,PeterPeter Van Roste
General Manager

CENTR - Belliardstraat 20, 1040 Brussels, Belgium
tel REDACTED - fax REDACTED
www.centr.org – twitter: REDACTEDCENTR Comment on the IANA Coordination Group (ICG) Proposal to Transition the Stewardship ofthe Internet Assigned Numbers Authority (IANA) Functions from the U.S. Commerce Department’s
National Telecommunications and Information Administration (NTIA) to the Global
Multistakeholder Communityi
7 September 2015CENTR would like to thank the ICG for the proposal and the opportunity to comment. This comment
is submitted on behalf of the CENTR community, which comprises more than fifty European countrycode top-level domain name registries.
Conditional status of the proposal
With reference to X010, CENTR recommends to provide more details for a scenario in which theconditions set forth by the CWG are not met. This might also be necessary on a secondary level, incase one or more of the ICANN Supporting Organisations (SOs) and/or Advisory Committees (ACs)retract their conditional support. In particular, we would be interested in seeing alternative timelines
for the entire process in these cases.
It is understood that even in a scenario where the conditions set forth by the CWG are met, timelineof the CCWG Workstream 1 process will be a key factor. However, there seems to be some
confusion on whether implementation or mere agreement is needed across the proposal (X011: …
that the dependencies … are concluded …; X012: Once the CCWG has concluded its work …; X026:
the finalisation of CCWG Workstream 1 …). We believe that it might be highly improbable that theimplementation of the additional accountability mechanisms is completed by the time of thesubmission of the ICG proposal to the NTIA. Therefore, we would suggest that this matter is fully
clarified and, if necessary, different scenarios are presented.
IPR aspects
The CENTR community does not believe there is incompatibility between the different proposals
from the Names, Protocols and Numbers communities in respect to IP rights. We have read withinterest ICANN’s Board Statement in this respect and we agree it is an acceptable interim solution.
While we believe the proposal to transfer IP Rights to an entity that is independent from the IANA
Functions Operator is acceptable, we suggest to run an impact assessment of the proposal toinvestigate the effects of a possible separation on the IP Rights and how this would eventually
impact the operational aspects of the IANA Functions.
NTIA Criteria
The CENTR community agrees that the current proposal matches the NTIA criteria, specifically:

1.

Broad community support: We believe there have been extensive efforts to ensure all
stakeholders could contribute to the discussion. For the Names community the unanimous
approval by the SOs and ACs underlines the broadest possible support. In addition, theproposal from the CWG also received CENTR’s support. We would like to highlight that theCENTR membership includes 10 ccTLDs that are not members of the ccNSO.

2.

Support and enhance the multistakeholder model: This model relies on existing aspects ofthe multistakeholder model and well combines them. In addition, it strengthens the model
as it will include an additional layer of accountability mechanisms.

3.

Maintain the security, stability, and resiliency of the Internet DNS: As the current IANA
Functions Operator will remain the same over the transition, there is no immediate impact
on the security, stability and resiliency of the Internet DNS. The CENTR Community believes
that the additional accountability mechanisms that will be built-in provide sufficientguarantee that the security, stability and resiliency is ensured in the long term.

4.

Meet the needs and expectations of the global customers and partners of the IANA services:
For the Names Community, service levels will improve as the process for Root Zone changes
is streamlined. Given the already high level of customer satisfaction from our community,
we feel confident that our future expectations will be met.

5.

Maintain the openness of the Internet: There are no elements in the proposal that would
undermine the current level of openness of the Internet.

6.

Does not replace NTIA role with a government or inter-governmental organization: The roleof the NTIA is not replaced by a government or inter-governmental organisation but isreplaced by a model involving both its direct customers and the multistakeholder
community.

Separation scenarios
For the sake of completeness, the CENTR community strongly recommends that the different
separation scenarios are listed and include a risk assessment at a high level. These scenarios should
cover the situation where one, two or all three customers of the IANA Functions Services (Names,Protocols and Numbers) would decide to move their services portfolio to a different operator. This
could be combined with the proposal for a risk assessment related to IP Rights, but goes beyond
that. In particular financial impacts need to be carefully evaluated and should be included in theproposal.
Service Level Expectations (SLEs)
CENTR wants to point out that the CWG proposal didn’t yet include the Service Level Expectations as
they were not completed at the time the proposal was sent to the ICG. We strongly support theinclusion of SLEs by the CWG and believe their implementation should be prioritized.
SLEs are crucial for IANA Functions Customers and as such should be part of the complete ICG
proposal. We therefore believe that a placeholder – similar to the one on the accountability
conditions – in the ICG proposal would be useful until the SLEs have been agreed upon andintegrated in the CWG’s final proposal.

i

https://www.ianacg.org/calls-for-input/combined-proposal-public-comment-period/