Name: Juan Carlos Hernández Wocker

Organization: Instituto Federal de Telecomunicaciones (IFT)

Submission ID: 142

Dear ICG:

Regarding your call for public comment about IANA Stewardship Transition Proposal thathas been closed yesterday September 8, we appreciate so much if you can consider ourcomments attached.

We believe that this important process require a very high participation in order to really
recognized that all the stakeholders interested in the process had have the opportunity topresent their views of this exercise.

Thank you very much.
General Coordination of International Affairs

URL: https://comments.ianacg.org/form
IANA Stewardship Transition Proposal - Public comment forum
Disclaimer: ICG will use the information received for the analysis of public comments only. Participants´
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Commenter´s Data
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Name: Juan Carlos Last
name:* Hernández Wocker
E-mail: * REDACTEDCountry/economy: Mexico
Organization: Instituto Federal de Telecomunicaciones (IFT)Questions concerning the proposal
1)

Proposal completeness and clarity: Is the combined proposal complete? Each of theoperational community proposals contains aspects to be completed in the future when
the proposal is implemented. Is the combined proposal specified in sufficient detail suchthat it can be evaluated against the NTIA criteria?

Proposals submitted by each of the operational communities are clear on the transition processthat each community will carry out in relation to the functions they perform. However, it isconvenient to have the combined proposal version in order to observe in a clearer and moretransparent manner the details of the aspects that will be jointly fulfilled by the operationalcommunities.
Likewise, each of the proposals submitted by the communities has a specific appendix detailing
how they comply with the requirements set forth by the NTIA, and therefore, the proposal isspecified in sufficient detail so as to be evaluated against the NTIA criteria:
Broad community support: each proposal details the inclusive process undertaken toguarantee engagement of all stakeholders in the proposal development, thus allowing awhole community support for each proposal.
Supporting and enhancing the multistakeholder model: each proposal details the way inwhich the multistakeholder model has been implemented for the development ofproposals that would be submitted to the ICG, however,we have noted that the model will need to be more balanced as to stakeholder orcommunity aspects as well as regional aspects in order to allow the enhancement ofproposal combination and awareness.
 Keeping DNS security, stability and resiliency: the transition process will have no impact
whatsoever on the DNS security and stability.
 Meeting the needs and expectations of global IANA service customers and partners: theproposal seeks to guarantee the participation of all stakeholders in the proposal
development so that partners´ needs and expectations are met. However, this aspectshould be carefully implemented and evaluated in the short run so as to ensure thatpartners` needs and expectations are addressed.
 Keeping Internet openness: None of the proposals has impact whatsoever on Internet
openness.
Not replacing the NTIA role by a government- led or intergovernmental organization
solution: none of the proposals submitted by the communities provides theestablishment of an inter -governmental organization; nevertheless, the proposed model
continues to be under the jurisdiction of one single government, then once the NTIA role
has been replaced, the PTI is required to, at least, evolve into a public or privateinternational law entity which shall not be subjected to any government.

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 among
the functions resolved in a workable manner?

The document analysis indicates that the operational community proposals could work together
in one single proposal, but incompatible arrangements will only be observed once the three
proposals are combined into one.
In case of existing any conflicting overlaps or function incompatibility, it is considered that:they could only be resolved through the communication among the three operational
multistakeholder support, and to this end, a calendar of
short and medium term reviews could be timely submitted with clear indicators in order to identify
incompatibility details.

3)

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?

Each of the proposals submitted by the operational communities is considered to have
independent accountability mechanisms to ensure IANA functions continuity,
since each proposal includes oversight, review and dispute resolution mechanisms,

Which will lead to the IANA functions transition without impacting the ongoing operation.
However, it is believed that every accountability mechanism proposed by the operational
communities must guarantee the following principles:Any information owned by the entities established shall be public; therefore, any act
deriving from the exercise, competence and mechanisms of such entities must bedocumented in order to guarantee that accountability elements are adequate andindependent for the performance of the IANA functions.
 Information access mechanisms and expeditious review procedures must be guaranteedso as to avoid gaps in general accountability related aspects.
Finally, the principle of maximum public access regarding the functioning and managementof accountability mechanisms set forth by each operational community must bepreserved.

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 conflict or concern is observed regarding workability assessments included in theoperational community proposals. Compilation into one proposal will be required in order toguarantee there are no conflicts or 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 youbelieve are necessary.

The proposal is considered to meet the NTIA criterion of supporting the multistakeholder model
because each of theprocesses undertaken by the operational communities for thedevelopment of points of views were carried out using available IT resources to facilitate
stakeholder engagement, and by strengthening agreements in a consensual manner. However,in order to enhance the model, participation of even local multistakeholders from different
developing and underserved countries is required, which will call for further activities to improvethe understanding and discussion of the proposals submitted.
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.

None of the proposals submitted by the operational communities is considered to affect
DNS security, stability and resiliency since none of them proposes operational changes

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
are necessary.

The report and executive summary are considered to reflect the necessary aspects of theproposal so there are no additional comments on this regards.

General questions
12)

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

It would be advisable to submit a proposal containing the input of the operational communities.