Name: Ricardo Pedraza‐Barrios

Organization: Colombian Government

Submission ID: 139

Dear Sir/Madam,
Please accept our submission from the Colombian Government to the Public Comment Callon IANA Transition Proposal.
Technical problems on our Internet connection prevented us on submitting our comments
on time.
I attach the form filled out.
Yours sincerely,
RicardoRicardo Pedraza‐Barrios
AdvisorInternational Affairs and Communications
Communications Regulatory Commission, CRC Calle
59 A Bis No. 5 ‐ 53‐ 9th Floor; Building Link Siete
Sesenta Bogota, D.C., Colombia.
Phone: REDACTED
Fax: REDACTED
Zip Code: 110231
Web Page: www.crcom.gov.co
E‐mail: REDACTEDURL: https://comments.ianacg.org/form
IANA Stewardship Transition Proposal - Public comment forum
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Commenter´s Data
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Name *:
Last name * Pedraza-Barrios
E-mail * REDACTEDCountry/ economy: Colombia
Organization: Communications Regulatory Commission (CRC)

Questions concerning the proposal1)

Proposal 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 CWG, CRISP and IANAPLAN working groups have developed proposals following thespirit of the criteria set forth by the NTIA. In turn, The IANA Stewardship Transition
Coordination Group (ICG) has had the role of assembling them into one single proposal. It is
worth noting that the scope of the ICG mandate in relation to this role is:“The assembly effort involves taking the proposals for the different components and verifyingthat the whole fulfills the intended scope, meets the intended criteria, that there are no missing
parts, and that the whole fits together. The whole also needs to include sufficient independentaccountability mechanisms for running the IANA function.” 1
Therefore, the ICG composition offers the highest level of "expertise" in the different fields ofknowledge involved in this operational and technological integration effort. Consequently, it isappropriate noting that the ICG work has been of such a quality that the assessment can be
carried out following the NTIA criteria.

1 Source: https://www.icann.org/en/system/files/files/charter‐icg‐27aug14‐en.pdf

It would be appropriate to point out that in order for the proposal to be considered complete, thelevel of consensus reached within the working group as well as within the other three operational
community working groups has been widespread. In this sense, it is essential that the proposalof the working group on Enhancing ICANN Accountability -Work Stream 1 has obtained thesame level of general consensus. We do understand that, in a multistakeholder model, absoluteconsensus is an ideal, and that general consensus is an indication of acceptance by the different
stakeholders.
Given the fact that the whole proposal may still lack certain aspects that will derive from legal andlegislative specifications resulting from the proposal implementation, the lack of absoluteconsensus on the some of the operational community proposals is understandable. The same
completeness principle applies to the integrated proposal. However, the Colombian government
believes that a thorough effort has been made by the operational communities, and that the highly
skilled members of the IANA Stewardship Transition Coordination Group (ICG) have equally
managed to deliver a comprehensive proposal within the agreed time frame so as to have a publiccomment process and make the final adjustments deemed necessary by the multi-stakeholdercommunity.
2)

Compatibility and interoperability: Do the operational community proposals work together in asingle proposal? Do they suggest any incompatible arrangements where compatibility appears to
be required? Is the handling of any conflicting overlaps among the functions resolved in aworkable manner?
Compatibility and interoperability related issues in the operational community proposals havebeen a responsibility covered by the IANA Stewardship Transition Coordination Group (ICG)
mandate, as above mentioned. Therefore, we assume said differences, if any, have been adjusted
as a whole. However, in the combined proposal, we have noticed the particulars regarding IANA
brand and domain name management, which we believe may be revised by the parties at the timeof implementation.

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?
Operational community proposals have included service quality management and oversightmechanisms, and these mechanisms were adequate, independent and properly supported to run theIANA functions.
As it was mentioned before, the scope of the IANA Stewardship Transition Coordination Group(ICG) mandate includes ensuring that accountability mechanisms are fully integrated into thecombined proposal.

Nevertheless, considering the fact that under the combined proposal there would be a new Boardof Directors, this board will be able to define any new additional accountability aspect that mayarise. Similar to ICANN, IANA will be able to regularly revise its accountability enhancements.
4)

Workability: Do the results of any tests or evaluations of workability that were included in theoperational community proposals conflict with each other or raise possible concerns when
considered in combination?
As part of the scope of the ICG mandate for integration, the following has been set forth:
The assembly effort involves taking the proposals for the different components and verifyingthat the whole fulfills the intended scope, meets the intended criteria, that there are no missing
parts, and that the whole fits together. The whole also needs to include sufficient independentaccountability mechanisms for running the IANA function.” 2
Therefore, the ICG composition offers the highest level of "expertise" in the different fields ofknowledge involved in this operational and technological integration effort. Then, we consider
that the integrated proposal has solved every conflict or eventual gap that may have appeared inthe original proposals.
However, it should be noted that the legal feasibility of the proposal is an aspect that, weunderstand, goes beyond the scope established by the different CWG, CRISP and IANAPLAN
working groups. Thus, it is essential that this aspect be thoroughly analyzed by subject matter
experts. In fact, this legal feasibility analysis must be carried out based on the bylaw
amendments recommended by the proposal of Work Stream 1 on enhancing ICANN
accountability. Particularly, aspects to facilitate the subcontracting of PTI and other necessarycomponents should be taken into account, and they should guarantee IANA legal independence
within the proposed structure.

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 arenecessary.
Yes. The change in the contractual relationship between one single government and ICANN toa multistakeholder entity is the best evidence of this.

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.

2 Source: https://www.icann.org/en/system/files/files/charter‐icg‐27aug14‐en.pdf

Yes. The accountability mechanisms, service quality and Internet openness proposed by theoperational communities in their proposals pose an operational scheme that aims at maintaining
and, in some cases, improving DNS security, stability and resiliency.

7)

Do you believe the proposal meets the needs and expectations of the global customers andpartners 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 orpartner of the IANA services.
Yes, it meets their needs and expectations. Throughout this year, many meetings and discussion
fora about the needs and expectations of customers and partners of the IANA services have been
held, which shows ICANN community´s interest and openness to adjust a proposal taking into
account such needs.
It is worth mentioning that the Colombian government is an IANA customer through the countrycode domain name management operator ".co”.

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.
We believe the proposal does maintain Internet openness, understanding that this openness refers
to the potential technological evolution of domain names, IP addresses and Internet protocol
parameters. Likewise, the new IANA organizational scheme does not present, a priori, projects
to expand the installed identifier database. However, it can be deduced that multistakeholder
consultation and engagement mechanisms would allow to maintain this Internet openness.

9)

Do you have any concerns that the proposal is replacing NTIA’s role with a government-led orinter-governmental organization solution? If yes, please explain why and what proposal
modifications you believe are necessary. If not, please explain why.
Taking into account that the proposal presents a multistakeholder engagement plan, there are noconcerns on this particular issue.

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.
The proposal implementation calls for further detail on the inter relationship among thecomponents of the stewardship transition, the adjustments deriving from Work Stream 1 onenhancing ICANN accountability, and related contractual considerations.

Since one of the NTIA criterion is to maintain Internet openness from the perspective of domainnames, IP addresses and Internet protocol parameters, and to preserve DNS security, stability andresiliency, this aspect would be one the greatest challenges for the new model. However, ICANN
multistakeholder community has proved, so far, its capacity to keep a balance, which gives theColombian government confidence that NTIA criteria will be preserved in the future.

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.
As we have indicated before, the IANA Stewardship Transition Coordination Group (ICG)
composition offers the highest level of "expertise" in the different fields of knowledge involvedin this operational and technological integration effort. Hence, we consider that the integrated
proposal has been developed with the required quality.

General questions12)

Do you have any general comments for the ICG about the proposal?
The Government of Colombia wishes to express its deep appreciation to the members of the ICG
for their effort to integrate the proposals of the CWG, CRISP and IANAPLAN working groups towhom appreciation is equally expressed for their excellent work.
The close relationship between the integrated proposal for the IANA stewardship transition, andthe proposal to enhance ICANN accountability fully conditions the implementation feasibility of
the first one in relation to the second one. For our government, preserving those aspects related tothe GAC advisory nature in relation to the ICANN Board, in Work Stream 1, is of vital
importance for any formula intending to amend ICANN bylaws.
Notwithstanding any further input addition or adjustment in relation to the process during theupcoming ICANN meeting, the Colombian Government reserves its right to provide further
feedback, and supports the position to be accomplished by general consensus through the GAC.