From: "Chris Disspain" <ceo@auda.org.au>
To: <DNSTransition@ntia.doc.gov>
Date: Thu, Jul 6, 2006 10:14 AM
Subject: Docket No. 060519136-6136-01 - submission

To The Department of Commerce, US Government,

au Domain Administration Ltd (auDA) is the Manager of .au, the Australian Country Code Top Level Domain (ccTLD). auDA is a not for profit company with members from both the supply and demand sides of the domain name industry and is endorsed by the Federal Government of Australia. auDA has a contract with ICANN and is a member of the Country Code Name Supporting Organisation (ccNSO).

auDA makes the following submission to the NTIA Notice of Inquiry.

The DNS White Paper principles are still relevant. It is always valuable to consider new principles or reconsider the existing ones.
However, it should be noted that operating in accordance with the articulated principles has led to the advance in Internet
technology and the expanded global reach of the Internet. Further, care needs to be taken when considering the WSIS discussions.
These are centred on Internet governance generally whereas this Inquiry relates specifically to the management of the Internet DNS.

ICANN has achieved sufficient progress in its tasks, as agreed in the MOU, for the transition to take place by September 30, 2006.
Many of the core tasks and milestones have already been achieved and significant progress has been made towards the completion of
the balance.

The core tasks and milestones are still relevant. We do not believe it is appropriate to introduce new or revised tasks. If the
current tasks and milestones are deemed to have been completed or achieved to a satisfactory level then transition should take place
in accordance with the MOU. As to time frame and method, a transition plan should be prepared by ICANN with input from key
stakeholder groups.

We are intimately involved in the ccNSO and believe that significant progress has been made over the last 2 years in respect to
ccTLD managers participation. The formation of the ccNSO, its increasing membership, its guidance to ICANN on 'contracts' with ccTLD
managers which has led to the Accountability Framework alternatives now being entered into all indicate effective involvement in the
ICANN process.

It appears that the gNSO is also enabling stakeholder groups to become involved in the ICANN process.

Mechanisms exist in ICANN's structure to deal with improved involvement. For example, the gNSO is currently going through an
independent review.

Participation can always be expanded and improved. For example, the current interface between the ccNSO and the Government Advisory
Committee needs work to ensure an open dialogue on issues of relevance to both. The key is to ensure that ICANN and the various
supporting organisations and committees recognise the need for improvement and have mechanisms in place to ensure it happens. The
ICANN structure with its ever developing processes and review mechanisms is equipped to ensure this occurs.

Currently work is being done by IANA on automating the root management requests as far as possible. This work is being done in
conjunction with ccTLD managers and with the involvement of the joint ICANN/ccNSO IANA Working Group. This is the best method to
achieve greater efficiency and responsiveness whilst at the same time addressing public policy and sovereignty matters.

It is important to draw a distinction between Internet DNS management and Internet governance generally. In respect to the Internet
DNS, we believe that the current ICANN structure, whilst by no means perfect, gives the best opportunity to ensure the ongoing
stability and integrity of the DNS infrastructure whilst allowing for a bottom-up processes in a competitive environment.

In respect to Internet governance, we await with interest, the results of the first Internet Governance Forum and reserve our
judgement until we have seen those.

We believe that the time has come for the US Government to step back from its 'oversight' role and transition from the MOU so that
the domain name system is independently controlled.

Neither the United Nations nor any body under their auspices are appropriate bodies to control Internet DNS management. The open,
transparent, bottom up, consensus based model that has been developed within ICANN over the years is not perfect and is still
developing and improving but it is the model best suited to the task of managing the DNS.

We understand the concerns of many ccTLDs and their governments about the perceived control of the US Government and the perceived
'US centric' nature of ICANN. We believe that once the US Government has stepped back and transitioned the Domain Name System to the
independent control of ICANN, it will be possible for ICANN to move swiftly to deal with the 'US centric' perception.

Chris Disspain
CEO - auDA
ceo@auda.org.au
www.auda.org.au