Name: Konstantinos Komaitis

Organization: Internet Society (ISOC)

Submission ID: 32

To Whom It May Concern:
Please find attached the comments of the Internet Society on the the Proposal to Transition
the Stewardship of the Internet Assigned Numbers Authority (IANA) Functions from theU.S. Commerce Department’s National Telecommunications and Information
Administration (NTIA) to the Global Multistakeholder Community
Respectfully submitted
Dr. Konstantinos Komaitis

Internet Society Comments on theIANA Stewardship Transition Proposal

03 SEPTEMBER 2015

The Internet Society (ISOC) commends the progress made by the global Internetcommunity on the IANA Stewardship Transition and the associated issues of ICANN
accountability. We congratulate the IANA Coordination Group (ICG) and the Cross
Community Working Group (CCWG) for their tireless efforts to produce proposals forcommunity review and comment.
We firmly believe that the time is right to globalize the IANA functions and that a
successful transition will reinforce the value of the collaborative, multistakeholder model1.
As the Internet Society, alongside leaders of the technical community, noted back in
March 2014, “The Internet technical community is strong enough to continue its role, whileassuming the stewardship function as it transitions from the US Government”2.
The Internet Society is a trusted, independent source for Internet information, thought
leadership and advocacy for a global, open Internet. We are also the organizational homefor the Internet Engineering Task Force (IETF). With a principled vision, a substantial
technological foundation and a global presence, the Internet Society is a long-standing
advocate for a decentralized, community-driven approach to the design, deployment andoperation of the global Internet. The core principles that have guided ISOC for over twenty
years are also the fundamental characteristics that have enabled the Internet to serve as aplatform for seemingly limitless innovation around the globe.
In its March 2014 announcement3, the United States government National
Telecommunications and Information Administration (NTIA) identified the Internet Society
as a "directly affected party" to this process. ISOC has two seats on the IANA Coordination
Group (ICG) and has been actively participating in all IANA-related discussions in thethree operational communities, as well as the ICG, over the past year.
The ICG has asked the public to review the combined transition proposal and submit
comments on whether and how it meets the criteria established by NTIA. The InternetSociety recently published an analysis of the NTIA IANA Functions Transition Principles(often referred to as the NTIA criteria) in which we noted that these principles are theproducts of global consensus and that they have been ingrained in the Internet’s
architecture from its earliest days4. Our comments on the combined proposal should beseen in light of the IANA stewardship transition principles and our perspective as a global
and diverse organization with deep roots in the Internet technical community.
In submitting these comments to the ICG, our aim is twofold: first, to support thoseelements that make the proposal workable from an operational perspective; and, second,1

http://www.internetsociety.org/news/internet-society-board-trustees-encourages-continued-trustmultistakeholder-process-iana
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http://www.internetsociety.org/news/internet-technical-leaders-welcome-iana-globalization-progress
3
http://www.ntia.doc.gov/press-release/2014/ntia-announces-intent-transition-key-internet-domain-namefunctions
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to make some observations about how the details of implementation of this new structure
will affect the operations and performance of IANA over the long term. We anticipate thatthe community will continue its work to address public comments received through the ICGand CCWG processes and, in particular, will concentrate on sorting out concerns over theimplementation aspects of the proposal.
As we review the ICG proposal together with the CCWG proposal, we note that theproposed structure is complex. We would note with concern, that, as the complexity of thesystem increases, we run the risk of losing transparency in the overall decision-making
processes.
It is crucial that both sets of recommendations work together and, after implementation,that the resulting system meets the IANA Functions Transition Principles. The real test ofthe NTIA principles is not in the proposal but rather in the “running code” – do we get thedesired result once the implementation is complete?
Support and Enhance the Multistakeholder Model:
The principle that any acceptable IANA Stewardship transition proposal must “support andenhance the multistakeholder model” means that the outcome must ensure that:a) The bottom-up, consensus based processes used by the Internet’s operational
communities regarding the global management of the IANA functions remain inplace.
b) The IANA functions are not subject to capture by any single set of stakeholders.
Collectively, the ICG proposal clearly represents the outcome of discussions conductedunder the unique multistakeholder processes of the relevant communities. The various
processes were transparent and open; mailing lists were inclusive and publicly archived;
and, throughout the process, communities held open virtual and face-to-face meetings andopen teleconferences. This lends credibility and legitimacy to the outcomes.
The result of this multistakeholder process in the ICG is a structure in which theoperational communities maintain their bottom-up consensus processes with regards tothe IANA functions; they also maintain their ability to make their own arrangements andagreements for the performance of the IANA functions.
We do note, however, that the CCWG accountability proposal requires heavy reliance on
one community (the names community), which may impact how the IANA can perform allof the functions in a reliable and predictable way. This is particularly the case when it
comes to decisions regarding the budget, strategic/operational plans, and bylaws
changes. It is essential that the needs and expectations (i.e. funding, operational security,etc.) of the other operational communities with respect to the performance of IANA be3WWW.INTERNETSOCIETY.ORG

taken into account. It is also important that the accountability proposal does not upset theexisting balance between the communities and/or between specific stakeholder groups.
Maintain the Security, Stability and Resiliency of the Internet DNS:
A key purpose of the IANA functions is to ensure global uniqueness in the allocation ofInternet names, numbers, and protocol parameters. Ensuring that the operation of theregistries is stable and secure contributes to the overall security, stability and resiliency of
the DNS root and other IANA functions.
Operationally, the ICG proposal maintains the appropriate separation between policy
development and implementation. The organizational change to ensure independence ofoversight is important and the proposal foresees the need to ensure appropriate staffing,
resourcing and know-how to run the IANA functions. The proposal also includes animportant shared commitment to performance and performance metrics that is crucial forthe ongoing security and stability of the IANA functions operation. Finally, the current
proposal allows the three functions to continue to evolve together in a way that facilitates
coordination among registries and contributes to the overall stability of the IANA.5
ICANN has two different but inter-related roles for which it is responsible in the current
operations of IANA. The first relates to policy development for domain names and thesecond is to perform the IANA functions. We agree with the ICG that some aspects of theproposed ICANN accountability model will have implications for both the policy
development process and the IANA functions. These linkages create the immediate needfor the communities to come together in order to ensure that those aspects of the new
accountability model are coherent and they do not impact the stable operations of theIANA functions.
It is clearly within the purview of the ICG and CCWG to communicate and find constructive
ways to address these dependencies and find a timely way forward; indeed, given ourcollective commitment to multistakeholder, bottom up processes for governing these
critical technical Internet functions, it is the responsibility of the global Internet community.
Moreover, the issue regarding the proper home of the IANA trademarks and the IANA
domain names (iana.org; iana.net; and, iana.com) remains unsettled. The Internet Society
agrees that the IANA-related intellectual property rights should be held by an independent
entity in order to ensure that these assets are used in a non-discriminatory, stable andpredictable manner for the benefit of all communities, users and the Internet. The IETF6
and the CRISP7 team have both indicated that they consider the IETF Trust to be an
acceptable candidate for holding the trademark and domain. Further, the IETF Trust has5

https://www.iab.org/wp-content/IAB-uploads/2011/04/2011-03-30-iab-iana-noi-response.pdf
http://www.ietf.org/mail-archive/web/ianaplan/current/msg01659.html
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said that it would be willing to hold intellectual property rights related to the IANA function8.
Given the experience of the IETF Trust in holding, maintaining and licensing certain
existing and future intellectual property and other property used in connection with theInternet standards process and its administration, we believe that the IETF Trust has thecompetency and legitimacy to serve as this independent entity. The licensing policy
considerations that would accompany a transfer of the IPR for the operations of IANA are
substantive in nature; it will be important to carry out a process to identify the concerns ofthe parties and for achieving community consensus on these matters.
Finally, we agree with the ICG that there is an outstanding issue with regard to the Root
Zone Maintainer (RZM), a role currently performed by Verisign. The ICG states that someform of agreement between the RZM and the IANA Functions Operator (IFO) for the Root
Zone management process will be essential when NTIA withdraws from the Root Zone
Management process.
In this regard, we have taken note of the “Root Zone Administrator Proposal Related to theIANA Functions Stewardship Transition”. In that proposal, the current NTIA authorizationrole is replaced by an authentication role performed by ICANN. While the technical detailsof the transition proposal seem prudent, we do have a question regarding theimplementation aspects of this change. Conceptually, NTIA’s current authorization roleacts as an audit step for change requests. From our reading of the proposal, it is unclear
whether this audit function remains post-transition and, if so, where it would live within thenew structure (in the IFO or another part of ICANN). It is our view that the audit function
offers a useful check in the review of change requests to the Root Zone file and issomething that should be replicated within the new processes.
Meet the needs and expectations of the global customers and partners of the IANA
services
Like any high quality service, the post-transition IANA arrangements should continue tosupport the performance of the IANA functions in a predictable, reliable and responsiveway, consistent with operational excellence. They should also continue to be performed ina neutral and transparent manner in line with customer needs and expectations.
The three operational communities have all confirmed that they are satisfied with theperformance of the IANA functions by the IANA department of ICANN. The combined
proposal, with the addition of the Post Transition IANA (PTI), is meant to ensure that theIANA functions will continue to be performed in line with customer expectations.
Each of the IANA functions is associated with a community that has a direct operational orservice relationship with the IANA functions operator, which includes the right of each
operational community to select a new entity for the performance of the IANA functions as
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a last resort. This relationship is ensured through contractual agreements – in the form ofMemoranda of Understanding and Service Level Agreements. These contractual
agreements provide important clarity and reflect the needs and expectations of theoperational communities.
In the ICG proposal, the operational communities recognize the need to either conclude or
update contractual agreements with ICANN for the provision of the IANA functions in order
to align with community expectations. As the various contractual agreements become
ready, they should proceed. Unless the various agreements are in place in a time
appropriate to meet the respective needs and expectations of each of the communities,
the mutual rights and responsibilities between the parties will be unclear and might lead toa post-transition tussle. Unresolved, this could create a high degree of uncertainty andresult in instability of the IANA functions.
Maintain the Openness of the Internet
Openness has long been a core value of the Internet system. With respect to the narrowrole of IANA in the Internet, openness ensures that the processes by which policies are set
by the IANA operational communities are open to anyone wishing to contribute.
Furthermore, information on the identifier allocations made by the IANA function itself is
freely available on the Internet. Similarly, within the numbering and protocol communities,
policy development remains open to all participants and is closely coupled with the open
standards development process used in the Internet Engineering Task Force (IETF) for thecreation of technical standards.
The IANA registries are open and in the public domain and the ICG proposal makes nochange to this approach. Nothing in the ICG proposal restricts the openness of policy
development processes within each operational community.

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The transition proposal must not replace NTIA’s role with a government-led or intergovernmental organization solution
The current proposal does not replace NTIA’s role with a government-led or intergovernmental organization. Within each community, there are mechanisms in place toprevent capture by governments.
We agree that well constructed accountability mechanisms within ICANN can and willcontribute to the integrity of IANA. As indicated above, however, these very accountability
mechanisms rely heavily on one community (the names community). In this regard,-­‐

Does the accountability recommendation sufficiently balance the interests of all
stakeholders to safeguard the stability of the ICANN structure and to prevent
capture by any interest group, governments in particular, after implementation?

Further, the proposal seems to create internal layers in favor of judicial redress instead ofmultistakeholder, community-based consensus. The relevant communities should carefully
consider the long-range implications of such an approach.
Issues of implementation
In conclusion, we would like to draw attention to the need for timely resolution ofoutstanding issues with regards to the implementation of the various processes,mechanisms, and rules that relate to IANA. Details related to the structure of the new PostTransition IANA (PTI) and the various bodies supporting it (e.g. CSC, IFR, etc.),
implementation aspects of the CCWG proposal (as it relates to IANA), a plan tosuccessfully conclude the SLAs, and a resolution of IANA-related intellectual property
rights have yet to be fully fleshed out. We urge the community to determine:-­‐How these implementation details will be addressed in a timely fashion to thesatisfaction of all communities in a way that continues to meet the principles set
forth by NTIA; and,-­‐How all the communities will remain involved in the implementation of the new
structure in an appropriate manner.	  

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Conclusion
The Internet Society submits these comments in the spirit of cooperation and collaborationand in support of an IANA stewardship transition. We have raised a number of questions
that we believe merit further reflection within the communities. Resolution of these issues
will strengthen the overall outcome of the transition process and, we believe, will provide
increased confidence in the continued openness, stability and administration of the critical
IANA functions.
Again, we would like to congratulate all the communities and the ICG for their hard workand for their continuous effort to develop a proposal for the successful transition of theIANA functions away from the United States government. The Internet Society remains
committed to a successful transition and supportive of the globalization of the IANAfunctions. We will continue to assist the efforts of the global Internet community towards a
successful transition, which can help reinforce the value of collaborative, multistakeholder
model.9

Internet Society
Galerie Jean-Malbuisson, 15CH-1204 Geneva
Switzerland
Tel: +41 22 807 1444
Fax: +41 22 807 1445
www.internetsociety.org
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USA
Tel: +1 703 439 2120
Fax: +1 703 326 9881
Email: info@isoc.org

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