Name: Rahul Sharma
Organization: Data Security Council of India
Submission ID: 130

Hi Team,
PFA inputs by Data Security Council of India on the subject. Attached are1.
2.

DSCI comments using ICG template
DSCI comments using DSCI template

Kindly use as per your requirements.
If you need more details, please feel free to get back to us.
Kind Regards,
Rahul Sharma | Senior Consultant
DATA SECURITY COUNCIL OF INDIA (DSCI) | A NASSCOM® Initiative
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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 field

First Name *: Rahul
Last Name *: SharmaEmail Address *: REDACTEDCountry/Economy: India
Organization: Data Security Council of India

Questions Concerning the Proposal as a Whole
1)

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?

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?

3)

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

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?

Questions Concerning NTIA Criteria5)

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.

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.

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.

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.

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.

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.

Questions Concerning ICG Report and Executive Summary
11)

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.

General Questions
12)

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

DSCI Comments
The initial calls for democratization of the global Internet governance (IG) were made at theWorld Summit on Information Society (WSIS) in 2005. The need for democratization re-­‐ignited
in 2013 with growing discontent amongst various nation states and stakeholder communities on
unilateral oversight of the United States over IG matters, and Internet Corporation for Assigned
Names and Numbers (ICANN’s) autonomy. Four critical aspects, which were a bone ofcontention, among others, were – US government’s unilateral control, legal jurisdiction inwhich ICANN resides and to which its decision are subject to, lack of a credible accountability
mechanism of ICANN Board, and National Telecommunications and Information Administration(NTIA’s) role as an authorization entity for performing changes in DNS Root Zone File.

Rising voices led to NTIA, Department of Commerce (DoC), US announcing transition of its
Stewardship role that it had been playing for many years, subject to certain conditions beingmet. After NTIA’s announcement of 14 March 2014, ICANN launched a ‘multistakeholder’
process and discussion to gather community views and inputs on the principles andmechanisms for transitioning of NTIA's stewardship of the Internet Assigned Numbers Authority(IANA) functions. DSCI commends the Domain Names (CWG-­‐Stewardship), Numbering
Resources (CRISP Team) & Protocol Parameters (IANAPLAN Working Group) communities, andsubsequently IANA Stewardship Transition Coordination Group (ICG), for putting forth a
proposal to transition the Internet Assigned Numbers Authority (IANA) functions to a global,multistakeholder community.

The proposal, although detailed in many aspects, fails to address contentious issues that wereprimary reasons for initiation of the stewardship transition process. Any change to the current
ecosystem should address basic principles like stability, security, scalability, reliability andsmooth operation of the Internet, while enhancing the multistakeholder model. Following are a
few comments and observations on the draft proposal, which should be addressed before theproposal is finalized and shared with NTIA for implementation:
The proposal is silent on the issue of internationalization of ICANN. The community in its
deliberations to develop the proposal assumed that ICANN will continue to beheadquartered in US, and remain subject to US laws. Despite the jurisdiction issue being
highlighted by many individuals during the discourse, decision makers excluded themwith a presumption: a proposal that asks on changing jurisdiction of ICANN will not get
the sanction of the ICANN Board and NTIA. Thus, community efforts are leading to a
proposal that can be deemed satisfactory to ICANN Board and NTIA, not necessarily to a
proposal for benefit of global multistakeholder community, whose interest should beparamount. It is further strange to note that the Names community (CWG) proposed
establishing a Post-­‐Transition IANA (PTI), that will be an ICANN subsidiary and will
perform IANA functions operations through a contract with ICANN, with following
conditions:o PTI must be US owned and operated, incorporated and organized under US lawo Primary IANA functions must be performed in the US
o PTI must have a US physical address
By listing down such requirements, despite no such pre-­‐requisites mentioned, the ICG
proposal seems influenced and hampers prospects of internationalization of entities in
the Internet governance domain, and ultimately democratization of Internet. An entity
such as ICANN should be subject to International laws and not US laws.
Currently, ICANN’s role as performing IANA function through the NTIA contract keeps acheck (limited) on ICANN’s activities and actions. Changes in stewardship must beaccompanied by improvements in ICANN's accountability, possibly through astrengthened and well-­‐enforced external accountability mechanism. These aspects areintertwined and must be pursued in parallel. With a lack of established external
accountability mechanism through a strong entity, inactions and monopolistic nature ofoperations can rise. With no external oversight, there appears to be little check in place
to ensure that a multi-­‐stakeholder model will be preserved and strengthened.
Rather than an ICANN subsidiary PTI performing IANA functions through a contract byICANN (as mentioned in the ICG proposal), or an independent organization completely
unrelated to ICANN performing IANA functions through ICANN contract, amultistakeholder organization (any existing organization that is capable of performingthat role or establishing a new organization), to replace NTIA’s role would be an ideal.
Not only were discussions in this direction not taken up, but the focus of individuals
working on the proposal seems to have been on empowering ICANN by handing overNTIA’s stewardship role to ICANN, with above mentioned presumptions.

The NTIA stewardship transition proposal intended to replace NTIA’s stewardship role(that includes issuing IANA functions contract to ICANN), to the multistakeholder
community, and not empower ICANN which currently performs IANA function. The ICG
proposal seems to revise this role and hands over the contract issuing authority role toICANN, which is currently performed by NTIA. So as per the proposal, a third party
performing operations on contract (ICANN) would now be issuing contract to its
subsidiary PTI for performing IANA functions.
The ICG proposal assumes ICANN as the chosen body to perform NTIA’s role, without
also seeing ICANN as a stakeholder in the transition due to its current role.
One of the most important aspects, on who will authorize changes in Root Zone Filepost-­‐NTIA stewardship transition, remains unanswered in the proposal. Verisign
currently serves as the Root Zone Maintainer and performs the Root Zone Management
functions pursuant to a cooperative agreement with NTIA, while NTIA acts as Root Zone
Management Process Administrator.
This important and significant area is left untouched by the ICG proposal, but isseparately covered in the report prepared by ICANN and Verisign proposal outlining ahigh level plan to amend the NTIA’s administrative role associated with root zone
management.
When the contractor itself is changing, how can the contract and organization
performing the contractual function be left out of the scope of transition proposal? It isessential that it be adequately addressed to maintain security, stability and resiliency ofthe DNS operations.
Role of Customer Standing Committee (CSC) in respect of Parameter Function andNumber Function is not very well established in the proposal
Relationship between PTI and the numbering and protocol parameters communities,and ultimately Internet Engineering Task Force (IETF) and Regional Internet Registries(RIRs) is not adequately defined in the proposal
Globalization of Critical Internet Resources such as DNS Root Servers is necessary toperpetuate the idea of democratization of Internet and resources, and strengthening
the multistakeholder community. Currently, out of thirteen root servers, ten reside isUS, two in Europe and one in Japan. The ICG proposal should also discuss onredistributions of current Root Server infrastructure. If there is no technical limitation

now to increase the number of global DNS Root Servers, which seems to be the caseprima facie, major countries and regions with vast Internet population should have atleast one instance of original root server, and based on the requirements, ability to add
mirrors subject to DNS traffic.