Name: Pierre Bonis
Organization: AFNIC
Submission ID: 117

Please find attached Afnic’s submission to the ICG public comment.
Regards,Pierre BONIS Directeur Général Adjoint Deputy Chief ExecutiveOfficer

IANA Stewardship transition Proposal. AFNIC’s input.
1. Please provide your name:
Pierre BONIS
2. Please provide your affiliation:
AFNIC
3. Are you providing input on behalf of another entity (e.g. organization, company,government)? Yes/NoNo

Questions Concerning the Proposal as a Whole
1. Completeness and clarity: Is the combined proposal complete? Each of theoperational community proposals contains aspects to be completed in thefuture when the proposal is implemented. Is the combined proposal specified
in sufficient detail such that it can be evaluated against the NTIA criteria?
The proposal is complete to our point of view, and clear enough. It gives way to the three
Operational communities (naming, numbering, and parameters) to have a real oversighton the IANA functions, while maintaining stability and robustness of the overallmechanism. Nevertheless, as noted in X011, we fully support the idea that:“the names proposal is complete on the condition that the dependencies on ICANN-levelaccountability mechanisms(…)are fulfilled as specified in the names proposal.”

2. Compatibility and interoperability: Do the operational community proposals
work together in a single proposal? Do they suggest any incompatible
arrangements where compatibility appears to be required? Is the handling of
any conflicting overlaps between the functions resolved in a workablemanner?
We don’t see any incompatibility between the various parts of the proposal (better said,
we feel this is already a unique proposal by the three Operating communities)
3. Accountability: Do the operational community proposals together include
appropriate and properly supported independent accountability mechanisms
for running the IANA functions? Are there any gaps in overall accountability
under the single proposal?
The establishment of the PTI as a separate legal entity from ICANN, together with
Customer standing comitee and the Iana Fonction review process are strong mechanisms
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to guarantee and independent accountability mechanism run by the stakeholders
themselves. Together with the reinforced contractual link between the RIRs and ICANN,and with the continued contractual arrangements between IETF, IAB and ICANN, theIANA functions are all covered and strong mechanisms to maintain and strengthen theSLAs are in place. One should notice that ICANN being part of all proposals, at least as acontractor, need to see its own accountability mechanisms well defined.
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 you believe are necessary.
Yes, because it gives room to all stakeholders (being direct customers or indirect users) tohave a say on IANA performances, and a real power to change the IANA operator ifneeded.
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, because what works (the technical arrangements, the staff in charge and thecompetences needed) is reinforced with this proposal.
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. Ifnot, please explain why and what proposal modifications you believe arenecessary. Please indicate if you are a customer or partner of the IANAservices.
As a registry, direct customer of the IANA services, we thing the combination of the CSC
and of the IFR are satisfactory. Furthermore, we note that the redelegation appeals forCCTLDS are part of the policy, and in no way an operational mechanism, and that it’s of
the responsibility of the CCNSO and the regional organizations reaching to non CCNSOCCTLDs to elaborate a proposal, that isn’t needed before the transition take place.
8. Do you have any concerns that the proposal is replacing NTIA’s role with agovernment-led or inter-governmental organization solution? If yes, please
explain why and what proposal modifications you believe are necessary. Ifnot, please explain why.
Not at all.

General Questions2

Most of the remarks done by Afnic during the second call for comments launched by theCWG IANA stewardship are still relevant, especially:In the IFR, there should have an equal representation between CCTLDS and GTLDS, bothbeing direct customers and representing various local communities.
Afnic wants to size the occasion to thank all the participants, and particularly the CWG
IANA transition, for the great work, and is confident that, if the condition of a broadly
supported accountability framework for ICANN is met, this transition will take placesoon.
Afnic also want to share its full support to the CENTR submission.

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Afnic, is a multi-registry operator of the top-level domains corresponding to thenational territory of France (the .fr TLD and those of several of the overseasterritories) and of French projects for new Internet top level domains (TLDs).
Afnic is a full member of CENTR, the European CCTLD Regional organization.

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