[IANAtransition] Comments of China Internet Network Information Center (CNNIC)

Xiaodong Lee xl at cnnic.cn
Thu May 8 15:31:19 UTC 2014

On behalf of China Internet Network Information Center (CNNIC), hereby we
would like to take this opportunity to make our comments on ICANN’s Draft
of Proposal of the Principles and Mechanisms and the Process to Develop a
Proposal to Transition NTIA’s Stewardship of the IANA Functions. Due to
the significant impact of IANA transition to the global internet
operation, we support the principle that any decision-making related to
the approach and process of IANA transition should embody community
consensus and justifiably includes broader interests and concerns of
diverse stakeholders. The country code top level domain (ccTLD), as the
fundamental actors in the internet stability maintenance at the national
or regional level, are crucial stakeholders in the IANA function. To
develop a well-fledged proposal of IANA transition, we suggest the design
of the IANA transition process should give respect and full consideration
to the inputs of each ccTLDs. Therefore, we urge ICANN to extend the
public comment period and solicit more input from the ccTLD community.
Only in this way can we achieve a consensus-based multi-stakeholder
approach to IANA transition.

Our specific comments are as follows:

1. Comment Regarding to the Principles

In addition to the current 10 principles, we would like to reemphasize the
importance of “diversity” principle. Especially, we are concerning about
the diversity of the steering group members in terms of geography and
development level of their origin.

We support the statement in the draft that “care is taken by this
(Steering Group) selection process to ensure diversity and regional
representation”, so as to prevent the imbalance of regional seat
distribution in the Steering Group. In addition to this, we recommend that
the assignment of representatives from each region in the steering group
should follow an equitable proportional standard regardless of the
community each steering group member is representing.

Furthermore, we also would like to stress the importance of having
representatives from the developing countries in the steering group, which
will further ensure the openness, inclusiveness and global of IANA
functions transition policy and decision making process.

2 Comment Regarding to the Mechanisms

Besides the mechanisms mentioned in the draft proposal, we suggest ICANN
or IGF to set up various ad hoc platform/fora, where opinions and
suggestions from a broader sphere can be brought in and discussed in the
ICANN multi-stakeholder ecosystem. In addition, the steering group shall
duly publish public comment report and feedback to the community.

3 Comment Regarding to Steering Group Selection

According to the Draft Proposal, the steering group would be comprised of
representatives from each SO (ASO,ccNSO, gNSO) / AC (ALAC, RSAC, SSAC,
GAC) group within the ICANN community and the affected parties (IETF, IAB,
ISOC, NRO). After community members interested in serving submit a
statement of interest, the Chair of the ICANN Board and Chair of the GAC
will select the group members from this community similar to the approach
used for AoC reviews. Generally speaking, we support the member selection
mechanism used in AoC review, which not only guarantees the bottom-up
process, but also mind the whole picture to balance and coordinate
diversified representations of the steering community. In addition, we
suggest that, like the AoC review process, each AC/SO organization shall
endorse statement of interest of its member without any filtering. The
selection shall be the responsibility of the Chair of the ICANN Board and
Chair of the GAC according the standard of geographical and development
level diversity.

In addition, regarding to the assignment of steering group member as each
SO/AC and affected party has two seats, we are not fully convinced by this
absolute average method.  ICANN need to explain what kind of theoretical
basis or community suggestion has made ICANN think that such allocation
merits consideration and discussion. According to the latest data, the
count of ccNSO members is almost 150, ccTLD number around the globe is
close to 300. With the simple average method in the Steering Group seat
allocation, the demands from ccTLD and gTLD communities cannot be
represented fully and effectively. On the other hand, In the draft
proposal, ICANN recognizes IETF, IAB, ISOC and NRO as “Affected Parties”,
and allocated with them around 1/3 seats in the steering group. These
organizations are undoubtedly appropriate and important participants in
both ICANN’s multistakeholder model and IANA function transition process.
However, with only these four as affected parties, the requests and
opinions from the multistakeholder ecosystem can not be represented with
equitability and comprehensiveness. The importance of TLD registry
operators especially ccTLD community has failed to be properly reflected
as well.

4 Comment Regarding to Proposal Development Process

The proposal development process shall guarantee that the diverse opinions
and content delivered to the steering group are objectively expressed by
the steering group members. Specifically, with the current mechanisms, we
are not fully assured of whether the decision-making processes of the
steering group members are fully accountable to the community which they
are supposed to represent. We suggest that specific guidelines should be
set up to keep the impartial performance of the steering group. Filtering
of the community input by steering group members should not be acceptable
and every input received by a single member must be efficiently forwarded
to the entire group for consideration. Furthermore, in the transition
proposal drafting process, ICANN shall set up specific mechanisms and
guidelines to further guarantee impartial decision-making process of the
steering group members.

Best Regards,

Prof. Xiaodong Lee

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