Name: Tony Holmes
Organization: GNSO, Internet Services Provider and Connectivity Provider Constituency (ISPCP)
Submission ID: 64

Questions Concerning the Proposal as a Whole1) 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?

The proposal as a Whole is following the proposals of the three individual Operational Communities(OCs) which all are structured according to the RFP. As such – and with completing the still open
CCWG points outlined in Part 0, IV.B - the proposal is seen as complete and can be evaluated against
the NTIA criteria. However there are uncertainties seen whether the CCWG shall be able to findconsensus on all the open issues in time (e.g. the separability) which then could affect the overalltimeline.
Part 3 “Response from the Protocol Parameters Registries Community” is designed as a “DraftResponse”. On Page 179 it is indicated that “This Internet-Draft will expire on July 10, 2015”. Wesuppose that a valid – not expired – document is going to be incorporated in the final proposal.

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?

The three OCs have different views on who should be responsible for the IANA Functions Operator(IFO) after the transition. With the PTI construct and the SLAs a viable solution seems having beenfound. But this still contains a potential of future conflicts in particular with regards to theseparability. This should be clarified before moving to the implementation phase, althoughrefinement may be feasible at that later stage.

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?

Definitely the accountability issues still open re WS1 have to be resolved by the CCWG and approvedby the CWG; see also response to 1)

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?

None have been identified at this stage

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 proposal modifications you believe
are necessary.

Yes indeed! The proposal was developed within the multistakeholder framework of ICANN and theglobal community. The development of the proposal was one of the best sources of better
understanding between the participating communities. We therefore share the expectation thatcross-community multistakeholder process in this area will benefit in future from this experience.

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, we hope – and believe.
ISPCP support the work undertaken to measure future Service Level Expectations with the highquality level provided at present. This work is to be completed and incorporated in the proposal. We
understand that through the control and accountability mechanisms imposed continuous operational
excellence can be secured which is crucial with regards to the security, stability and resiliency of thesystem.
Important will be the smooth transition of the IANA organization with its present staff. No basic
structural change is needed.

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.

The global customers and partners of the IANA services are mainly represented through the 3 OCs.
With the consensus found – after completion of the still open issues – the services will continue to beprovided at the level expected.

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.

At present we do not foresee the change to the management of the IANA functions resulting in any
negative consequences for the openness of the Internet.
However, ending the discipline of the NTIA regularly placing the IANA functions contract withICANN – a contract that is able to and does in fact place requirements on ICANN that have
implications beyond the management of the IANA functions – does have the potential for
consequences that would impair the openness of the Internet.
This issue is being addressed, and solutions developed, within the Cross-Community Working Groupfor ICANN Accountability (CCWG-Accountability). Our support for this transition proposal iscontingent upon the successful completion and implementation of the CCWG-Accountability’s
Workstream 1 proposal.

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.

The entities to be established in order to take over NTIA’s various roles with respect to the IANA
services are not recognized as led by governments. We believe the future participation of
governments has been incorporated like the one of any partner.

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.

As long as the new bylaw and contractual regime to be implemented continues we believe that willbe the case. No projection beyond 5… years!

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.

YesGeneral Questions
12) Do you have any general comments for the ICG about the proposal?