[AfrICANN-discuss] NRO Comments to US Dept of Commerce on JPA

[Lillian O. Sharpley]

http://nro.net/news/response-ntia-noi.html

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
Chairman NRO

pdf version attached

Posted on behalf of the NRO,

Lillian Sharpley
Communications Area Manager
AfriNIC
(230) 466 6616
www.afrinic.net

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