Name: Andrew Sullivan

Organization: Internet Architecture Board (IAB)

Submission ID: 72

To the IANA Stewardship Transition Coordination Group:
The Internet Architecture Board (IAB) appreciates the opportunity to respond to the ICG's"Proposal to Transition the Stewardship of the Internet Assigned Numbers Authority(IANA) Functions from the U.S. Commerce Department’s National Telecommunications andInformation Administration (NTIA) to the Global Multistakeholder Community"(henceforth, "the proposal").
The IAB strongly supports the transition of IANA Stewardship from NTIA to the Global
Multistakeholder Community.
The IAB supports the overall ICG proposal. We believe that it meets the criteria laid out by
the original NTIA announcement (http://www.ntia.doc.gov/press-release/2014/ntiaannounces-intent-transition-key-internet-domain-name-functions) and subsequent
remarks. In addition, the proposal was developed in accordance with the early remarks
from the IAB about how to proceed (https://www.iab.org/wp-content/IABuploads/2014/04/iab-response-to-20140408-20140428a.pdf). The proposal wasdeveloped by the three directly affected communities, and existing coordination
mechanisms were used to ensure overall coherence. As did other groups, the IAB
appointed direct participants to the ICG. The resulting proposal demonstrates themultistakeholder process functioning correctly. We believe that the proposal maintains thesecurity, stability, and resiliency of the global DNS and maintains the openness of theInternet.
Naturally, there are some details to be worked out during implementation. The IAB
acknowledges and agrees with the IETF IANAPLAN working group consensus that the draft
ICG proposal does not pose problems for the protocol parameters function or interferewith the development or safe use of IETF standards.
As the party responsible to the protocol parameters community for the oversight of theprotocol parameters IANA functions, the IAB wishes to draw particular attention to some of
the remaining details. In addition, in its role as with regard to the overall architecture of
the Internet, the IAB wishes to share some additional remarks.
1. Details particular to the protocol parameters registries
The IAB is pleased that the proposal reflects the consensus of the IETF, and we believe thatthe proposal is therefore adequate to deliver the necessary stability for the protocol
parameter functions. We look forward to the necessary positive affirmations that theregistry contents are in the public domain and that any future transition would beappropriately supported, as requested in ¶3062 of the proposal.

We observe that the ICG proposal creates a new ICANN affiliate to perform the IANA duties,
the Post-Transition IANA or PTI. Notwithstanding that, we understand that the existing
MoU between the IETF and ICANN will continue without change. That is, the MoU remains
the basis for the administration and maintenance of the protocol parameters registries.
This means that ICANN will be effectively subcontracting the performance of its obligations
to the PTI. We have no objection to this mode of operation because we understand that theobligations themselves will remain with ICANN. As a matter of implementation, we expect
ICANN to make provisions for the continued delivery of service at the level of historicalnorms. The IAB observes that the ICG proposal confirms that expectation; it is expressed
especially clearly in ¶3061. We are pleased that the creation of PTI does not affect thecontinued operation of any of the existing MoU, including the ability of ICANN or the IETF
to end that agreement with appropriate notice.
2. Remarks more general to IANA
The IANA function function is purposefully limited and intrinsically constrained to lie
outside of policy determination, yet the IANA is still a critical function. Therefore, largechanges to how it operates must be undertaken with care.
The IAB understands that the plan to create the PTI is intended to address issues identified
by the names community. Some portions of the proposal, including much of Part I,
contemplate significant participation by the various operational communities in newbodies and committees. However, the IETF continues to be satisfied with the existingworking arrangements with the IANA staff and their delivery of the protocol parameter
functions. We believe these arrangements will remain as effective as before the transition.
Because the existing MoU and annual SLAs govern the relationship with ICANN as relates tothe IANA functions, we have no current intent to place IETF representatives on additional
committees whose primary duty is to judge the effectiveness of IANA (or ICANN moregenerally) for other IANA functions, though we are thankful for the opportunity to provide
representatives to monitor the operations.
The IAB currently has liaison relationships with the ICANN Board and RSSAC, andadditional liaison relationships can be established with other communities if this ismutually desired. Perhaps more importantly, the IAB and IETF have many crosscommunity informal relationships that enable cooperation without resorting tobureaucratic channels of communication. Informal and loosely-coupled coordination has
worked well in the past, and it produced the coherent ICG proposal without formal liaisonsamong the communities. We believe that this web of relationships is a strong expression of
the multistakeholder model, and that there is no need to concentrate these relationships
within new ICANN structures. The IAB does not oppose additional formal links in principle
if they are found to be useful in the future, and we believe we have all of the necessary
mechanisms for adding them. In general, however, we prefer informal coordination andcommunication among the communities, and we generally prefer to avoid creating
additional organizational structures. We believe this organizational model reflects the way
the Internet works.
Respectfully submitted,
Andrew Sullivan
For the IAB