Name: Gideon Rop

Organization: DotConnect Africa Trust

Submission ID: 44

Dear IANA Stewardship Transition Coordination Group (ICG) Team,

Please find attached DotConnectAfrica Trust' submission to the Call for Public Comment on
IANA Stewardship Transition Proposal.

Best Regards,__________________________
Gideon Rop

Project Manager
DotConnectAfrica Org
www.dotconnectafrica.org

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Fax:+254-020-2731146
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Africa, and will sponsor, establish and operate a TLD registry with global recognition andregional significance dedicated to the needs of the Pan-African and African community.
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DotCOnnectAfrica Trust Comments to the IANA Stewardship Transition Proposal- Public Comment FormDisclaimer: The ICG will not use the information collected for any purpose other thananalyzing public comments. Submitters’ names, affiliations, and comments will bepublic.
Identifying Information* Indicates required field
First Name * Gideon
Last Name * Rop
Email Address REDACTEDCountry/Economy
Organization: DotConnectAfrica TrustQuestions Concerning the Proposal as a Whole
These are comments submitted by DotConnectAfrica Trust.
DCA Trust General Comments:
In our submission on the 2nd Draft Proposal by the CWG-Stewardship1 it was our view that theDraft Proposal has highlighted an "Internal to ICANN Model" of a wholly-owned subsidiary - thePost Transition IANA (PTI) - that belongs to ICANN. This implies that the PTI will only be
accountable to ICANN as its only controlling parent. This conceptual framework is faulty. The
proposal assumes that ICANN is absolute owner without also seeing ICANN as a stakeholder inthe Transition, albeit with the status of being 'first amongst equals'.
We also mentioned that ICANN’s accountability track record has been of major concern because
in most cases has not been able to uphold accountability to the public and to theMultistakeholder community, and especially in the advent of the new gTLDs.
While making our submission to Congressional Hearing on "Stakeholder Perspectives on theIANA Transition"2, DCA Trust stated that there will be need for additional time so as to enable

1

DCA Trust comments to the CWG-Stewardship 2nd Draft Proposal http://forum.icann.org/lists/comments-cwgstewardship-draft-proposal-22apr15/pdfvqtrqfKCtB.pdf
2DCA Trust submission to Congressional Hearing on "Stakeholder Perspectives on the IANA Transition
http://www.circleid.com/posts/20150710 dca submission congressional hearing stakeholder perspectives iana/

the United States Government Accountability Office (GAO) to properly review the IANA
Transition proposals; and until such a review is completed and a formal report submitted by theGAO to Congress, the US-NTIA should retain all existing DNS responsibilities. This is so as toallow time for proper and reflective deliberation; and time for the enactment of relevant
governing legislation to shepherd the entire process.
We are of the view that this proposal still needs enough time for proper analysis anddeliberation towards an acceptable model that does not award ICANN all the powers inmanaging the DNS resource without enough oversight.

1)

Completeness and clarity: Is the combined proposal complete? Each of theoperational community proposals contains aspects to be completed in the futurewhen the proposal is implemented. Is the combined proposal specified in
sufficient detail such that it can be evaluated against the NTIA criteria?

Comments: There is need to restructure the proposal in an understandable manner that can beutilized by the mutistakeholder community so that they are able to comment appropriately.
It is important to also stress that ICANN was supposed to only facilitate the Transition Process
on behalf of the NTIA, but the Draft Proposal that has been developed by the IANA StewardshipTransition Coordination Group has now positioned ICANN as the principal IANA Functions
Operator, with both policy making and operational responsibilities; the latter role to beexercised through a wholly-owned ICANN subsidiary. There is therefore no proper separation ofpowers - and such a structure would lack the necessary checks and balances required for properaccountability. The PTI will only be accountable to ICANN and not to the community that is
expected to take responsibility for the Post IANA Transition system2)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 workable manner?

Comment: I think the proposal is still complicated and needs further analysis and simplification
so that it can be understood by the end user who does not know much about internet
governance3)

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?
Comment: Item X021 states that while the names proposal calls for the IANA functions operator
to be transferred to the PTI, the PTI will be an affiliate (subsidiary) of ICANN and ICANN will be
responsible for the stewardship of the PTI. Hence operational roles are maintained. The proposal
envisages the names aspect of the current NTIA oversight and contracting authority istransferred to ICANN. The separation of PTI as a subsidiary will ensure the independence of thatoversight role from the contractor providing the service.
DCA Trust notes that "Internal to ICANN Model" of a wholly-owned subsidiary - the Post
Transition IANA (PTI) - that belongs to ICANN implies that the PTI will only be accountable toICANN as its only controlling parent. This conceptual framework is faulty. The proposal assumes
that ICANN is absolute owner without also seeing ICANN as a stakeholder in the Transition,
albeit with the status of being 'first amongst equals'.

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 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 proposalmodifications you believe are necessary.

Comment: The proposal still does not meet the criterion of the multistakeholder model, this isbecause the community as yet has not been involved fully in the development of this proposal,
largely because of the timeframe allocated to producing an agreeable documents that can meet
the NTIA requirements
There is still need for enough time to be allocated and better awareness made so that thisdrafting can go outside the usual ICANN circles and into the hands of the community who needto understand their role first. Especially from the developing nations such as Africa which are yet
to participate fully in this drafting.

6)

Do you believe the proposal maintains the security, stability, and resiliency of theDNS? If yes, please explain why. If not, please explain why and what proposal
modifications you believe are necessary.

Comment: ICANN needs to ensure that the current records of attacks and breaches on its
systems be addressed at a precautionary and not reactionary level.

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 and what proposal modifications you believe are necessary.
Please indicate if you are a customer or partner of the IANA services.

Comment: As stated in the comment on enhancing the multistakeholder model, this proposal
falls short in supporting and meeting the needs and expectations of the global customers andpartners of the IANA services, more opportunities should be provided to the stakeolders to beable to make valuale and actual comments and changes to the composition of decision makers.
For independence and purpose of accountability and non-interference, the CSC should not be part of thegovernance structure of ICANN. The CSC should have an independent board that is comprised of its
members to ensure that it is separately governed from ICANN. This would ensure that ICANN will not beable to influence, nor play any role in the, activities of the Customer Standing Committee.
The CSC's performance of the monitoring of the IANA Functions Operator Performance should also be
subject to monitoring and evaluation; and its activities subject to independent juridical review as may benecessary. This is to ensure that the CSC takes full responsibility and remains accountable for the workthat it is supposed to do.
The escalation of any matter that is within the purview of the CSC Escalation should be to the CSC'ssupervisory board.

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 are necessary.

Comment: This proposal needs to be modified to be able to allow community participation andnot just stakeholders who have been in the ICANN and internet governance realms. It needs tobe structured to allow the end users to feel the responsibility of effecting and improving change
in the oversight.

9)

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. If not,please explain why.

Comment: The proposal does not give enough assurance that it will be opne to accountability
and therefore there is task of putting ICANN in the hands of a body that will not be accountable
to anyone.

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 whyand what proposal modifications you believe are necessary.

Comment: No, until all assurances of accountability and transparency have been strengthened

Questions Concerning ICG Report and Executive Summary11)

Do you believe the ICG report and executive summary accurately reflect allnecessary aspects of the overall proposal? If not, please explain whatmodifications you believe are necessary.

General Questions
12)

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

Comments: There is need to allow for more time for the all the stakeholders to submit their
input and also give more awareness to the public to generate more input.