From: Patrick Vande Walle <patrick@isoc.lu>
To: <DNSTransition@ntia.doc.gov>
Date: Sat, Jul 1, 2006 7:27 AM
Subject: Comments on DNS Transition, Docket No. 060519136-6136-01

The Internet's value is created by the participation and cooperation of people all over the world. The Internet is global, not national. Therefore no single Government should have a pre-eminent role in Internet governance.

As the US reviews its contract with ICANN, it should work cooperatively with all stakeholders to complete the transition to a Domain Name System independent of US governmental control.

Point 63 of the WSIS Tunis agenda which states that "Countries should not be involved in decisions regarding another country’s country-code Top-Level Domain (ccTLD)." In effect, the US government will need to find a way to comply with this requirement, particularly with regard to the DoC/IANA contract. The US Government acknowledges this in its declaration of principles and it is now time it opens up negotiations with the international community to relinquish its involvement in other countries' TLDs and more generally on all TLDs.

Regarding the accomplishment of the MoU requirements by ICANN itself :

The 1998 DNS white paper stated that "An increasing percentage of Internet users reside outside of the U.S., and those stakeholders want to participate in Internet coordination" and also called for "seven members [of the board of directors] representing Internet users".

ICANN largely failed on this point. While the Internet industry (registries, registrars, RIRs and to a lesser extent ccTLDs) and governments are represented in the ICANN process, the domain names registrants and 1 billion individual users are nearly nowhere to be seen.
Nevertheless, we are convinced that the current ICANN multi-stakeholder process can be a good one, provided that all stakeholders, including individual users and domain name registrants, can take part in the decision.

The 1998 DNS white paper stated that "The cooperative agreement between NSI and the U.S. Government is currently in its ramp down period". However, 8 years later, we still have Verisign, the successor of NSI, as a major actor in the TLD administration, both as a TLD registry for two major domains and as a supposedly neutral root zone file manager role. This is a real conflict of interest that the Department of Commerce should address.

It is also unclear which technical tasks are performed by NTIA in the root zone management process and if they add any added value. One possibility would be to let the IANA perform the NTIA and Verisign parts in addition to its own, perhaps with some kind of peer review, the specific details of which should be discussed by the Internet community.

Respectfully submitted,

Patrick Vande Walle
Chairman
Internet Society Luxembourg