[CWG-Stewardship] RySG analysis of public comments

Kieren McCarthy kieren at kierenmccarthy.com
Fri Jan 9 18:32:30 UTC 2015


Important re: too complex.

I read all the comments and from those talking about it being too complex
came three things:

1. That there were too many interconnections between the four structures.
The CSC recommends to the MRT that you may need the IAP and so on. Way too
much unnecessary process.

2. That the structures as defined (or not defined) would create a whole
other set of processes: how members were selected, what their charter and
rules and methods would be, and so on. Far simpler, for example, would be
to say: the IAP aspect will be filed by the ICC (as it already does
ICANN-style arbitration); the CSC will be formed by the GNSO and ccNSO; the
MRT will be created on the same lines as, say, the ATRT i.e. let's not
create yet more new processes; stop reinventing the wheel.

3. That all the roles outlined weren't actually needed. The MRT doesn't
need to be there all the time since 99.9 percent of IANA transactions
simply happen without a fuss. You don't need a whole new CSC body because
they are already largely organized in other places. That the IAP may not be
necessary at all because various review and appeal mechanisms already exist.

So this is what people meant by "too complex" and I think this group should
really consider those remarks.

The ICANN community does have a tendency to over-engineer its policy
processes and build new bodies for every new issue. I think the comments
were saying: hold on there, take a step back and figure out whether all
this is really needed in reality or if we're building policy castles in the
sky.

Hope this is helpful.


Kieren



On Fri, Jan 9, 2015 at 9:10 AM, Avri Doria <avri at acm.org> wrote:

>  Hi,
>
> I have no problem seeing both of these as possibly be true simultaneously
> - I see no paradox.
>
> One can argue that the set of entities Contract Co, Contract holder, CSC,
> IANA, IAP, MRT,  and the interconnections between them makes for a complex
> architecture. And if one beleives that it is more complex than necessary to
> fulfill the IANA transition requirements, then it may be said that it is
> too complex.
>
> While also realizing that we have a ways to go, especially at the time the
> report was put out, defining the details of the entities and the nature of
> the communication and responsibility interfaces between those entities.
>
> Complexity without enough detail.
>
> avri
>
>
> On 09-Jan-15 11:53, Donna Austin wrote:
>
>  Milton,
>
>
>
> Based on our analysis, there were a significant number of comments that
> said the proposal was too complex and paradoxically the were also a
> significant number of comments that said the proposal lacked detail. We’re
> just reflecting what we read in the comments.
>
>
>
> Thanks,
>
>
>
> Donna
>
>
>
> [image: Description: Description: Description: ARI Logo]*D**ONNA AUSTIN*
> Policy and Industry Affairs Manager
>
>
>
> *ARI REGISTRY SERVICES*
> Melbourne *|* Los Angeles
> *P*  +1 310 890 9655
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>
>
>
> *From:* Milton L Mueller [mailto:mueller at syr.edu <mueller at syr.edu>]
> *Sent:* Friday, 9 January 2015 12:40 AM
> *To:* Kieren McCarthy; Donna Austin
> *Cc:* cwg-stewardship at icann.org
> *Subject:* RE: [CWG-Stewardship] RySG analysis of public comments
>
>
>
> I think the RySG did a good job of summarizing the comments from their
> point of view, but I can’t agree with one of their conclusions as to what
> should guide future efforts: the proposal is “too complex.”
>
>
>
> The statement that a proposal is “too complex” implies that one could
> develop a proposal that does the same things and has the same safeguards
> and is less complex.
>
>
>
> My response to that is: show me.
>
>
>
> We have already seen ALAC try and completely fail to deliver an
> alternative solution that is less complex.
>
>
>
> The “too complex” charge strikes me as one of those things that one would
> say after one’s first confrontation with the proposal. It was my first
> reaction, too. It is very easy to say, it is a kind of superficial
> response. The real issue is, however: what proposal is less complex, and
> how would it work? Until we have real, complete alternate proposals on the
> table the characterization of one proposal as “complex” is not very
> meaningful.
>
>
>
> If you think the status quo is not complex, you don’t understand what goes
> on in the current regime. The NTIA is embedded in the US government in a
> highly complex way; nothing simple about it.
>
>
>
> --MM
>
>
>
> *From:* cwg-stewardship-bounces at icann.org [
> mailto:cwg-stewardship-bounces at icann.org
> <cwg-stewardship-bounces at icann.org>] *On Behalf Of *Kieren McCarthy
> *Sent:* Thursday, January 8, 2015 11:44 PM
> *To:* Donna Austin
> *Cc:* cwg-stewardship at icann.org
> *Subject:* Re: [CWG-Stewardship] RySG analysis of public comments
>
>
>
> For what it's worth, I think this is a useful and succinct summary.
>
>
>
> I'm not entirely sure why the ALAC proposal has been highlighted twice
> when no other submissions have been specifically mentioned and there were
> other proposals. But apart from that this seems like a good path forward to
> me.
>
>
>
> Kieren
>
>
> -
> [sent through phone]
>
>
>
> On Thu, Jan 8, 2015 at 6:15 PM, Donna Austin <Donna.Austin at ariservices.com>
> wrote:
>
>  All
>
>
>
> In the interests of sharing, a group of RySG members conducted our own
> analysis of the comments submitted on the CWG Transition Proposal. Provided
> below are our conclusions and recommendations for next steps. Also attached
> is a document we prepared containing key excerpts of comments as they
> relate to various aspects of the proposal.
>
>
>
> Please accept this information in the spirit that it is offered—not as
> authoritative but as the result of an analysis developed by the RySG for
> our own purposes.
>
>
>
> We (Chuck, Stephanie, Sarah and myself) will be happy to answer any
> questions.
>
>
>
> *RySG IANA CWG Team Conclusions regarding ongoing work of the IANA CWG*
>
>
>
> The RySG believes that the following statements have very strong support
> in the community and hence can be used to guide future decisions by the CWG:
>
> A.      The current service of the IANA functions operator is
> satisfactory and ICANN should initially continue as the operator when the
> transition occurs.
>
> B.      The IANA CWG proposal as described in the request for public
> comments is too complex and does not contain enough detail.
>
> Of the four elements of the proposed IANA CWG proposal, there appears to
> be reasonable support for the CSC, MRT and IAP in some form, although not
> necessarily as described in the CWG proposal.
>
> The RySG believes that the following statements need further investigation
> and/or indicate areas where additional work is warranted:
>
>          i.            The overall structure of the CWG proposal.
>
>        ii.            Contract Co.
>
>       iii.            Internal to ICANN option
>
> *RySG IANA CWG Team Recommendations regarding Next Steps*
>
> 1.       Suggestions made by commenters should be evaluated based on the
> following criteria to identify which ones should be excluded, which ones
> should definitely be considered further and which ones need further
> investigation:
>
> a.       CWG principles
>
> b.      Would they contribute toward a simpler proposal?
>
> c.       Results of the two surveys.
>
>
>
> 2.       All alternatives to the CWG proposal should be examined in
> detail, not just the one proposed by the ALAC, to identify what
> alternatives or elements of the alternatives should be investigated further.
>
> 3.       An extension of the targeted time frame of at least 60 days
> should be requested from the ICG to allow for continued work and an
> additional public comment period after reasonable consensus is reached on a
> proposal for submission to the chartering SOs and ACs.
>
> 4.       The work of the IANA CWG and Accountability CCWG are properly
> dependent. The IANA CWG should have the opportunity to revisit the CWG
> Proposal, ALAC alternative, and other options once the outputs of
> Workstream 1 of the Accountability CCWG are provided and consider the
> implications for accountability as it relates to the performance of the
> IANA Functions.
>
> Thanks,
>
>
>
> Donna
>
>
>
> <image002.png>
>
> *DONNA AUSTIN*
> Policy and Industry Affairs Manager
>
>
>
> *ARI REGISTRY SERVICES*
> Melbourne *|* Los Angeles
> *P*  +1 310 890 9655
> *P*  +61 3 9866 3710
> *E  *donna.austin at ariservices.com
> *W  *www.ariservices.com
>
>
>
> *Follow us on **Twitter* <https://twitter.com/ARIservices>
>
>
>
> *The information contained in this communication is intended for the named
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>
> *From:* Gomes, Chuck [mailto:cgomes at verisign.com <cgomes at verisign.com>]
> *Sent:* Thursday, 8 January 2015 4:25 PM
> *To:* Donna Austin; Duchesneau, Stephanie; 'King, Stacey';
> rysg-iana-transition-cwg at googlegroups.com
> *Subject:* RE: Couple of Edits - Analysis Doc
> *Importance:* High
>
>
>
> Thanks to all three of you for the good edits. The first attachment is a
> redline that includes a couple edits I made to the second paragraph and a
> comment I added on page 3 regarding the fact that the last two sections
> will be sent to the CWG list. Please let me know if you see any problems.
> I also attached a clean copy.
>
>
>
> The third document attached is a final version of our excerpts.  Note I
> added an introduction.
>
>
>
> Donna – As our official rep, I think it would be good if you sent the
> documents as follows:
>
> ·         To the RySG & NTAG lists:
>
> o   Clean version of the analysis
>
> o   Excerpts document
>
> ·         To the CWG list:
>
> o   The last two paragraphs of the analysis.
>
> o   The excerpts document.
>
>
>
> Can you do that?
>
>
>
> Chuck
>
>
>
> *From:* Donna Austin [mailto:Donna.Austin at ariservices.com
> <Donna.Austin at ariservices.com>]
> *Sent:* Thursday, January 08, 2015 4:24 PM
> *To:* Gomes, Chuck; Duchesneau, Stephanie; 'King, Stacey';
> rysg-iana-transition-cwg at googlegroups.com
> *Subject:* RE: Couple of Edits - Analysis Doc
>
>
>
> I added the ‘internal to ICANN option’ as worthy of further consideration.
>
>
>
> Thanks,
>
>
>
> Donna
>
>
>
> <image002.png>
>
> *DONNA AUSTIN*
> Policy and Industry Affairs Manager
>
>
>
> *ARI REGISTRY SERVICES*
> Melbourne *|* Los Angeles
> *P*  +1 310 890 9655
> *P*  +61 3 9866 3710
> *E  *donna.austin at ariservices.com
> *W  *www.ariservices.com
>
>
>
> *Follow us on **Twitter* <https://twitter.com/ARIservices>
>
>
>
> *The information contained in this communication is intended for the named
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> privileged and confidential information and if you are not an intended
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> on it. If you have received this communication in error, please delete all
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>
>
> *From:* rysg-iana-transition-cwg at googlegroups.com
> [mailto:rysg-iana-transition-cwg at googlegroups.com] *On Behalf Of *Gomes,
> Chuck
> *Sent:* Thursday, 8 January 2015 11:58 AM
> *To:* Duchesneau, Stephanie; 'King, Stacey';
> rysg-iana-transition-cwg at googlegroups.com
> *Subject:* RE: Couple of Edits - Analysis Doc
>
>
>
> Thanks to both of you.  I will hold off a couple hours before finalizing
> and distributing.
>
>
>
> Chuck
>
>
>
> *From:* rysg-iana-transition-cwg at googlegroups.com [
> mailto:rysg-iana-transition-cwg at googlegroups.com
> <rysg-iana-transition-cwg at googlegroups.com>] *On Behalf Of *Duchesneau,
> Stephanie
> *Sent:* Thursday, January 08, 2015 2:15 PM
> *To:* 'King, Stacey'; rysg-iana-transition-cwg at googlegroups.com
> *Subject:* RE: Couple of Edits - Analysis Doc
>
>
>
> Thanks Stacy. Took a stab at tweaking/shortening a bit. I changed the
> recommendation slightly to provide the opportunity to actually revisit the
> proposals once WS 1 outputs are published. Please advise if this is not
> what we want. Also added revisiting other alternatives.
>
>
>
> *Stephanie Duchesneau*
> *Neustar, Inc. / *Public Policy Manager
> 1775 Pennsylvania Avenue NW, 4th Floor, Washington, DC 20006
> *Office:* +1.202.533.2623 *Mobile: *+1.703.731.2040  *Fax: *
> +1.202.533.2623 */* www.neustar.biz
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> *From:* rysg-iana-transition-cwg at googlegroups.com
> [mailto:rysg-iana-transition-cwg at googlegroups.com]
> *Sent:* Thursday, January 08, 2015 1:04 PM
> *To:* rysg-iana-transition-cwg at googlegroups.com
> *Subject:* Couple of Edits - Analysis Doc
>
>
>
> Okay….fairly wordy and it needs your edits, but here is my suggestion for
> basic language.
>
> Thanks!
>
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> <IANA CWG Public Comments Key Excerpts from the RySG - 8 Jan 15.docx>
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