[DTC CSC] Public Comments 228 & 231

[Martin Boyle]

ALAC comments (and comments from the IPC):


1.       Deliberations and output of the CSC will be completely transparent. Any exclusions must be explicitly documented:  I'm generally ok with this, but we should note that by its nature, some detail will need to be withheld (for example on security issues or on malicious and repeated ccTLD redelegation requests.

2.       We have discussed escalation at length.  We all recognise that escalation via the ccNSO & GNSO RySG will have problems associated with it.  However, approval for action does need to be given - we cannot leave it to a small and unrepresentative group to make decisions for the registries - and the only escalation that the CSC can require is because of failure in delivery of the service.  Hence the ccNSO and the RySG will simply be a gatekeeper - is this a problem of concern or is the CSC overreacting?  The multi-stakeholder process is invoked because there is a concern.  (This does not, I suppose, prevent other stakeholder groups calling for a special IFR or for raising their concerns with a periodic IFR.)

I would suggest that we respond along the lines of:

We agree with the comment that the CSC should work transparently.  Indeed we believe that a key role of the CSC should be to engage with the wider community.

This is one of the reasons why we believe that the CSC should not have the unilateral power to invoke further action.  As the first line mechanism, we believe that its main focus should be on ensuring remedial action, should deteriorating performance be identified.

However, we would note that there will be cases where complete transparency will not be appropriate and so the committee should have the discretion to maintain confidentiality in the rare cases where this is justified.  Examples of this could include issues of security (where it may be necessary to limit CSC members' access to such information) or where ccTLD redelegation requests are malicious action aimed at undermining confidence in the registry.

We recognise the issues associated with the proposed escalation path.  We strongly believe that a small committee such as the CSC should not be empowered to launch an escalation process on its own decision - it is, after all, simply a customer committee representing the customer community in ensuring the delivery of the IANA functions service to registries.  It seems reasonable that it should report back to the ccNSO and the RySG which would be able to assess from its membership whether the recommendation was appropriate.

We would note that (as this is the sole role of the CSC) the only grounds for a recommendation from the CSC for escalation are on the grounds of service failure of the operational performance.  If the decision is made to pursue escalation, we agree that the process then needs to become multi-stakeholder.

ALAC identifies the CSC as being the equivalent of the MRT from the previous model:  we do not believe that this is correct (the CSC was a separate entity in that model, too).  The MRT role in the current model is that performed by the IFR and it would be via the IFR that wider issues (ie beyond the performance of the IANA functions operator) would be addressed.

I think an additional comment is needed for the IPC.  This seems to think that "the CSC [should not be] run by and for the benefit of registries.  For similar reasons, it is important that the work of the CSC be open and transparent. The IANA Function is a critical resource used by every person or thing that interacts with the Internet.  As such, it is quintessentially a public resource, and its oversight should reflect that."  This again seems to be suggesting widening the CSC role into ground better covered by the IFR.  Phrases like "There may be times when the needs of the "customers" are not aligned with the global public interest" strike me as bizarre.  It needs a response so I suggest:

The CSC is solely about the performance of the function and we cannot imagine in this limited role where "the needs of the "customers" are not aligned with the global public interest."  We believe that the Customer Standard Committee role is of necessity limited and clearly defined to address performance issues only.  It is essentially a technical function.  Other issues are dealt with elsewhere in the proposed oversight model - in particular through the periodic and special IFR process.  For this reason, we do not believe that it is appropriate for the CSC to be fully multi-stakeholder:  this would risk the CSC losing its focus and duplicating or rivalling the work of more appropriate parts of the oversight model.

I'd welcome thoughts.

Martin
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