From: Annette Muehlberg <Annette.Muehlberg@web.de>
To: <DNSTransition@ntia.doc.gov>
Date: Thu, Jul 6, 2006 12:20 PM
Subject: ALAC Comments to NTIA Consultation on Transition of DNS Management

6 July 2006

Fiona Alexander
Office of International Affairs
National Telecommunications and Information Administration
1401 Constitution Avenue, N.W.
Room 4701
Washington, DC 20230

Dear Ms. Alexander,

The At-Large Advisory Committee (ALAC) of the Internet Corporation for Assigned Names and Numbers (ICANN), mandated by ICANN bylaws to convey the interests of global individual users, respectfully submits the following comments regarding the transition of the technical coordination and management of the Internet domain name and addressing system (Internet DNS).

ALAC is a global entity comprised of fifteen appointed members, three from each of five geographic regions: Africa, Asia/Pacific/Australia, Europe, Latin America/Caribbean Islands and North America. In addition, there are more than 40 organizations already accredited as "At-Large Structures (ALS)," which will eventually form Regional At-Large Organizations (RALOs) that will function as a bottom-up mechanism to support and engage in the ICANN policy process. As such, ALAC would like to emphasize the critical importance of openness, inclusion, transparency, and equal opportunity for all stakeholders of the world to share in the affairs of the global Internet identifier systems that ICANN is tasked to coordinate.

As the MoU between the US Government and ICANN expires in September this year, ALAC wishes to underline the unique opportunity the occasion offers to realize the original goals that led to the formation of ICANN. These include, inter alia, acknowledgement of the international nature of ICANN, support of the multi-stakeholder bottom-up approach to the management of ICANN, and the provision of viable and stable channels for the involvement of individual Internet users in the ICANN policy formation process. Measures must be implemented to ensure non-discriminatory availability of ICANN/IANA services as well as the opportunity for the involvement of global individual users in the ICANN process.

In its role as the voice of the individual Internet users, ALAC firmly believes that the current multi-stakeholder framework at ICANN should be further strengthened to allow more proactive involvement of end-users. The process to full participation of individual users through the ALAC/RALO (Regional At-Large Organization) mechanism is being undertaken at this moment. There is, however, a lack of incentives for the participants, especially a lack of direct involvement at the decision-making levels of ICANN. Therefore, we think that ICANN should find ways to implement adequate representation of individual users at the decision-making levels of ICANN so that a real multi-stakeholder framework is achieved.

In addition, we believe that no government should have a pre-eminent role in DNS management and exercise power over database changes and root-server data. We suggest that an institutional form should be found so that ICANN does not lie under the authority of any single national legislation.

We also strongly advocate transparency and openness in the process of making any structural change in the ICANN framework for the coming transition.

Respectfully submitted,

Annette Muehlberg
Chair
At-Large Advisory Committee
Internet Corporation for Assigned Names and Numbers