From: Martin Orr <martin@martinorr.name>
To: <DNSTransition@ntia.doc.gov>
Date: Fri, Jul 7, 2006 6:28 AM
Subject: Comments on the DNS Transition

In general, ICANN is operating reasonably well at present but it suffers
from a couple of significant problems. The most important of these, which
should be solved before any consideration is given to making it fully
independent, is the lack of representation of ordinary Internet users. Such
representation as exists is rather indirect, via the At-Large Advisory
Committee and Nominating Committee. This fails to achieve either the
principles of "private, bottom-up coordination" or of "representation" which
are supposed to motivate ICANN. Consideration should be given to seats on
the Board specifically allocated for this constituency, and perhaps also for
domain registrants. In a similar vein, there is a lack of transparency in
many of the operations of ICANN; minutes are are often slow to be published
or meetings held in camera. Efforts should be made to prevent this.

It should be noted that the Internet is fundamentally a global network, and
that its efficient operation is of crucial importance to all countries
across the world. Consequently it is inappropriate that any single country
should enjoy privileged control over a central part of its infrastructure,
such as ICANN. This is particularly true with regard to ccTLDs, as
recognised in article 63 of the Tunis Agenda for the Information Society:
"Countries should not be involved in decisions regarding another country’s
country-code Top-Level Domain (ccTLD)." National governments and registries
should be left completely free to set their own policies for the operation
of their ccTLDs, except for the most essential technical standards.

In order to achieve this, the United States should remove itself from its
current position of influence over ICANN as soon as possible, which creates
the perception if not the reality of improper interference. This does not
contradict the earlier recommendation that ICANN should not be made
independent, as oversight could be maintained through an international body
such as the International Telecommunications Union.

Respectfully submitted,

--
Martin Orr