[AfrICANN-discuss] NRO Comments to US Dept of Commerce on JPA
Lillian O. Sharpley
lillian at afrinic.net
Fri Jun 12 08:22:55 SAST 2009
The NRO's Comments Submitted to the United States Department of Commerce, National
Telecommunications and Information Administration's (NTIA) Notice of Inquiry (NOI)
11 June 2009
NOI: "Assessment of the Transition of the Technical Coordination and Management of the
Internet's Domain Name and Addressing System" [Docket No. 090420688-9689-01]
Date: 5 June 2009
The Number Resource Organization (NRO), representing the five Regional Internet
Registries (RIRs), welcomes the opportunity to comment on the United States Department
of Commerce NTIA's NOI.
The NOI addresses the upcoming expiration of the Joint Project Agreement (JPA) with
the Internet Corporation of Assigned Names and Numbers (ICANN), herein known as
the 'DNS Project'. It also raises key questions about the management and continued
stability of the Internet Domain Name System (DNS).
As indicated in our comment to the mid-term review, the NRO supports the expiration of
the JPA and believes that the objectives of the DNS Project have been sufficiently met
for this purpose. We offer the following additional comments for consideration.
1. The DNS White Paper highlighted four principles that would guide the DNS Project:
stability, competition, bottom-up coordination and representation. The NRO asserts
that these four principles must be retained as primary guiding principles for the
governance of ICANN after the expiration of the JPA.
2. Furthermore the White Paper articulated a primary goal of transition the
coordination of DNS responsibilities to the private sector, to enable industry
leadership in bottom-up and multi-stakeholder policy-making environment. The NRO notes
that in today's environment, a broader interpretation of the terms 'private sector'
and 'industry' must be applied, to encompass the objectives of a predominantly non-
Government multi-stakeholder Governance model which has been widely discussed and well
formulated in recent years.
3. The NRO asserts strongly that the success of the Internet is due precisely to the
Internet's established principles of bottom-up, industry self-regulation. We believe
that the processes and structures currently in place at ICANN can and do embody these
principles, and also, crucially, that they will permit and encourage whatever future
improvements are needed.
4. The DNS Project was founded on a belief that a 'private' coordination process
(namely in today's terms, a participatory multi-stakeholder process) would be more
flexible than a Government-based process. Further, it noted that a non-governmental
process would be able to adapt rapidly to meet the changing needs of the Internet and
its users. The NRO is confident that ICANN's established community has the capacity to
cope with future challenges and changes that may arise, and that continued sole United
States Government monitoring and input into ICANN's operation is no longer necessary.
5. The NRO fully supports the multi-stakeholder model of Internet operation, as
implemented within the ICANN framework. We support the participation and appreciate
the strong roles played by technical community organizations, including the IETF; by
the Internet industry through the Supporting Organisations; and by the Governments of
the world through the Government Advisory Committee (GAC). Further, the NRO emphasises
the continued need for the principles of access, diversity, openness and security, and
of community-based management of critical Internet resources, to be taken into
consideration when discussing the future of the Internet and its governance.
6. The NRO hereby calls upon to United States Government to conclude the JPA on its
expiry on 30 September 2009. We reaffirm our commitment to continue to work closely
with ICANN through the ASO MoU and other agreements, to ensure and safeguard the
bottom up policy development process that has proven highly successful as the
foundation of an open and transparent management of Internet numbering resources. We
note that with the termination of the JPA, these agreements will remain in place, and
their parties will continue to honour their tenets.
We hope that these remarks will be considered and have suitable bearing upon the
coming decision-making process within the US Government.
Finally, the NRO would like to thank the United States Government for its visionary
commitment to, and its great success in, transitioning the technical coordination and
management of the Internet's domain name and address system.
Adiel A. Akplogan
pdf version attached
Posted on behalf of the NRO,
Communications Area Manager
(230) 466 6616
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