Name: Richard Barnes
Organization: Mozilla
Submission ID: 127

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 isimplemented. Is the combined proposal specified in sufficient detail such that it can beevaluated against the NTIA criteria?

Yes. The proposal is sufficiently complete and the description of the future actions are sufficiently
clear that the overall proposal can be evaluated 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?

Yes. The individual community proposals are compatible with one another. The PTI / CSC / IFR
proposal from the names community, while different from the concrete structure envisioned by theproposals from the numbers and protocol parameters communities, is consistent with theirobjectives.

3) Accountability: Do the operational community proposals together include appropriate
and properly supported independent accountability mechanisms for running the IANAfunctions? Are there any gaps in overall accountability under the single proposal?

Yes. The proposal includes sufficient accountability mechanisms, both through the individual
stakeholder groups (e.g., IETF and RIRs) and through the IFR / CSC process.

4) Workability: Do the results of any tests or evaluations of workability that were includedin the operational community proposals conflict with each other or raise possible concerns
when considered in combination?

No concerns.

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 you believe
are necessary.

Yes. The proposal supports and enhances the multistakeholder model, both in the proposal itself andin how it was developed. The individual communities developed their proposals through open,
multistakeholder processes, and the combined proposal was assembled by ICG members from adiverse set of stakeholder groups. The proposed structure for IANA and its oversight finally places
IANA fully under the oversight of multistakeholder organizations and processes. It benefits fromexisting oversight processes that have been working well for years, and to the extent that newfeatures are introduced (e.g., the PTI), those new features are designed to incorporate input andparticipation from a variety of stakeholders.

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 youbelieve are necessary.

Yes. The proposal provides a good base for the continued security, stability, and resiliency of theDNS by relying for the most part on existing oversight and accountability mechanisms, and making
the minimum changes necessary to address the absence of NTIA in the process. As a result of thisconservative approach, the implementation of this transition proposal should have minimal effect onInternet users and operators.

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 why andwhat proposal modifications you believe are necessary. Please indicate if you are acustomer or partner of the IANA services.

Yes. By making minimal operational changes, the proposal will ensure that the existing processes
that have been meeting customers’ needs for years will keep working.
Mozilla is an indirect customer of IANA services with regard to all three lines of service: Mozilla
software relies on the protocol parameters registries in order to be interoperable with the rest of theweb. Mozilla uses several IP address blocks and Autonomous System numbers for its cloudoperations. And Mozilla maintains the Public Suffix List, which is based largely on the contents ofthe DNS root zone.

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.

Yes. As discussed above, the proposal strongly supports the multistakeholder model, which theInternet community has relied on for decades to guarantee an open Internet.

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.

No. This proposal moves IANA away from a model in which government has a leading role toward
one in which governments are included among many stakeholder groups.

10) Do you believe that the implementation of the proposal will continue to uphold theNTIA criteria in the future? If yes, please explain why. If not, please explain why and what
proposal modifications you believe are necessary.

Yes. The open, multistakeholder processes described in the proposal provide strong assurance thatIANA and its governance will be held accountable to the Internet community. The existingmechanisms that comprise the majority of the proposal have proven over decades that they work,
they keep the identifier registries stable, and they are not subject to capture.

Questions Concerning ICG Report and Executive Summary11) 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.

Yes, the ICG report and executive summary accurately reflect all necessary aspects of the proposal.

General Questions12) Do you have any general comments for the ICG about the proposal?

The IANA transition is good for the Internet. It was developed through open, inclusive processes in
the operational communities, and it meets all of the NTIA criteria. It should be sent to NTIA forapproval.