Name: Hibah Hussain

Organization: Google

Submission ID: 31

-________________________________________
Hibah Hussain | International Public Policy | REDACTED| Google DC

September 3, 2015
Via Electronic Mail: public­comments@ianacg.org
Re: Google Public Comment in Response to Proposal to Transition the Stewardship ofthe Internet Assigned Numbers Authority (IANA)
Background
Google commends the IANA Stewardship Transition Coordination Group (ICG) for
putting forth a proposal to transition the Internet Assigned Numbers Authority (IANA) functions.
Google supports the transition of the National Telecommunications and Information
Association’s (NTIA) stewardship role over the IANA functions to the global multistakeholder
community, provided that the conditions detailed by NTIA in its announcement regarding thetransition are met.1 We believe that the ICG’s proposal lays the groundwork for a successful
IANA transition. Furthermore, Google commends the ICG for engaging with all interested
stakeholders in developing the proposal and appreciates the proposal’s commitment tomultistakeholderism.
However, we believe that key aspects of the proposal would benefit from furtherclarification or refinement:1) The names community should consider potential weaknesses of the proposed
Post­Transition (PTI) IANA’s structure, and the ICG should clarify the relationshipbetween PTI and the numbering and protocol parameters communities.
Google supports the establishment of PTI, a separate subsidiary within ICANN that will
be responsible for performing the IANA functions. Furthermore, we agree that PTI’s remit should
be limited to the operational oversight of IANA naming functions. However, we believe that it
would be prudent to provide additional safeguards to ensure PTI remains accountable to thebroader multistakeholder community.
Google has warned against “replicat[ing] the complexity of the multistakeholder ICANN
Board at the PTI level,”2 and the ICANN’s Community Working Group (CWG) on the1Press Release, NTIA Announces Intent to Transition Key Internet Domain Name Functions, Mar. 14,
2014, available at
http://www.ntia.doc.gov/press­release/2014/ntia­announces­intent­transition­key­internet­domain­name­functions2
2nd Draft Proposal of the Cross Community Working Group to Develop an IANA Stewardship Transition
Proposal on Naming Related Functions 20, 21 (Apr. 22, 2015) (Second Draft Proposal), available athttps://www.icann.org/news/announcement­2015­04­22­enstewardship transition has explicitly recognized the importance of “maintain[ing] primaryaccountability at the ICANN level.”3 In order to promote clarity and accountability around roles
and responsibilities, Google recommends that the PTI Board be comprised of the ICANN Board
itself or a subset of ICANN board members. Otherwise, the proposal creates confusion
regarding who bears ultimate responsibility for ensuring that the IANA functions are performed
effectively, thereby making it difficult to hold IANA accountable for any performance failures.
Furthermore, the ICG should clarify the relationship between PTI and the numbering andprotocol parameters communities. Google understands that each of the three communities
associated with the IANA functions submitted separate proposals, and that PTI is not included in
the numbers and protocol parameters proposals. Rather, the numbers and protocol parameters
communities have proposed that they continue to work with ICANN as the IANA Functions
Operator (IFO). Given this inconsistency, the ICG should provide additional details to harmonize
the three proposals, including information regarding with whom the Internet Engineering Task
Force (IETF) and regional Internet registries (RIRs) will contract and whether or not the protocol
and numbers communities will participate in PTI’s proposed Customer Standing Committee(CSC) and IANA Function Review (IFR).
2) More detail is required on the proposed IFO separation process, including clear
standards for determining if and when separation is appropriate.
While Google agrees with the CWG’s decision to include a separation process in thenaming proposal, the CWG should provide more detail on the necessary criteria to invoke
separation and put forth clear standards for determining if and when separation is appropriate.
The separation guidelines outlined in Annex L include some information on what will occur “ifthe IFR determines that a separation process is necessary,”4 but do not provide any insight into
how and why the IFR might come to that decision.
In consideration of the significant risks that a separation process would pose to thestability and security of the DNS, we recommend that the CWG establish a substantive standard
for separation of the naming functions. More specifically, the CWG should specify that aSeparation Cross Community Working Group (SCWG) can be created only if the IFR deems
that the status quo raises significant concerns regarding the security, stability, and resiliency ofthe DNS. In order to recommend separation, the SCWG should then be required to make aclear finding that keeping the functions with the current IFO poses a substantial threat to thesecurity, stability, and resiliency of the functions and of the DNS as a whole. Furthermore, thisthreat should be substantiated by the Generic Names Supporting Organization (GNSO) andCountry Code Names Supporting Organization (ccNSO) in approving the initiation of separation
procedures. As a general rule, the ccNSO and GNSO should only approve the initiation ofseparation proceedings where the IFR evidences that more moderate remedial procedures
available to the IFR team could not reasonably address the deficiency.
3

Second Draft Proposal at 22; Google Public Comment in Response to Second Draft Proposal, May 20,
2015, available at http://forum.icann.org/lists/comments­cwg­stewardship­draft­proposal­22apr15/
4
Second Draft Proposal at Annex L.

3) The proposal should ensure a clear process for root zone management after theIANA transition.
After the transition, NTIA will no longer authorize changes to the root zone. As such, theproposal should identify a clear root zone management process that preserves the security,stability, and resiliency of the DNS. Verisign and ICANN’s recent proposal outlining a high­levelplan to “remove the NTIA’s administrative role associated with root zone management in amanner that maintains the security, stability and resiliency of the Internet’s domain namesystem”5 lays out a process for this transition and deserves consideration by the full community.
We agree on the importance of a smooth root zone management transition, and look forward tofurther development of this framework.
4) Enhancements to ICANN’s accountability must accompany the ICG’s proposed
stewardship changes.
As a global Internet company, Google is deeply invested in ensuring the underlying
security, stability, interoperability, resiliency, and openness of the Internet. We believe that inorder to achieve a successful IANA transition that safeguards these principles, the organization
carrying out the IANA functions must be accountable to its customers and the multistakeholder
community. As the ICG notes, its proposal is contingent on a parallel work stream to enhance
ICANN accountability. Bearing in mind that accountability reforms are a critical factor in theIANA transition, Google emphasizes that improvements to ICANN’s accountability are requisitecompanions to the ICG’s proposed stewardship changes.

5Verisign/ICANN Proposal in Response to NTIA Request,
http://www.ntia.doc.gov/files/ntia/publications/root_zone_administrator_proposal­relatedtoiana_functionsste­final.pdf.