From: "Danielle Nieuwenhuijse" <Danielle.Nieuwenhuijse@sidn.nl>
To: "DNSTransition@ntia.doc.gov" <'DNSTransition@ntia.doc.gov'>
Date: Fri, Jul 7, 2006 9:27 AM
Subject: Submission SIDN to the NTIA Notice of Inquiry

On behalf of Roelof Meijer, CEO SIDN, I would like to send the
submission of SIDN to the NTIA Notice of Inquire, see letter below:

From:
SIDN
Roelof Meijer
Utrechtseweg 310
PO Box 5022
6802 EA Arnhem
Phone: +31 26 352 55 00
Email: roelof.meijer@sidn.nl

Arnhem, 6 July 2006

To:
Mrs. Fiona Alexander
Office of International Affairs
National Telecommunications and Information Administration
1401 Constitution Avenue
Room 4701
Washington DC 20230, USA.

Subject: Request for Comment on the Continued Transition of the
Technical Coordination and Management of the Internet Domain Name and
Addressing System

Dear Mrs. Alexander,

SIDN is the registry for the .nl country-code top level domain, which,
with approximately two million registered domains, is one of the world's
largest and most successful ccTLDs.

As one of the founding members of the ccNSO, SIDN has been closely
collaborating with ICANN since it's creation with the objective to
assure availability, accessibility, security, overall quality and
further development of the internet in general and the .nl name-space in
particular.

As the Chief Executive of SIDN, I welcome the opportunity for
stakeholders to give input to the process of Continued Transition of the
Technical Coordination and Management of the Internet Domain Name and
Addressing System. As full and active member of Centr, the Council of
European National Top level domain Registries, we have contributed to
the response to the Request for Comment that Centr has submitted on
behalf of its members.

In addition to the submission by Centr, I would like to take the
opportunity to clarify the specific position of SIDN on the issues
raised.

We believe that the original principles of stability, competition,
private bottom-up coordination, and representation are not only still
relevant, but have gained additional relevance in light of the
developments as the advance in Internet technology, the expanded global
reach of the Internet, and the international dialogue, including the
discussions related to Internet governance at the United Nations World
Summit on the Information Society. In particular, the expanded
international reach of the Internet can best be accommodated and further
supported by these principles. We believe that management of the DNS is
best served in the private sector and wholly endorse the view of the UN
Secretary General at the World Summit on the Information Summit: "I
believe all of you agree that day-to-day management of the Internet must
be left to technical institutions, not least to shield it from the heat
of day-to-day politics".

One of the most important aspects of ICANN's role with respect to ccTLDs
is providing the core technical service known as the IANA function. As
the reliability of the function is of utmost importance for the
functioning of the Domain Name System as a whole, we believe that
ensuring its proper performance and adequate service levels must be
paramount when considering a time frame for transition.

SIDN is a strong supporter of effective participation of ccTLDs in the
ICANN process and we note with satisfaction that the ccNSO has been
created to provide a forum. However, to date, the ccNSO has not
attracted the majority of European ccTLDs and consequently cannot yet be
seen as a means of effective ccTLD participation. We note the steps that
have been taken to amend the ICANN bylaws with respect to the ccNSO and
urge ICANN to explore and enact what it can further do to make the ccNSO
the truly inclusive and representative organization originally
envisaged.

Regardless of this, it is important that ICANN establishes an effective
method of processing the input of ccTLD registries in planning and
executing the IANA functions. It lies in the nature of performing the
IANA function to be accountable and responsive to ccTLDs irrespective of
ccTLDs' individual relationship with ICANN and/or supporting
organisations.

ICANN has made considerable progress since its establishment but further
improvements are needed. We have been encouraged by recent steps to
automate the IANA function, and improve its operational efficiency.

We look forward to further progress by means of realisation of the
objectives relevant to the ccTLD community concerning operational and
organisational excellence, as formulated by ICANN in its 2006/07 Annual
Operating Objectives .

Relationships between governments and ccTLD managers follow diverse
models. Decisions relating to ccTLDs are to be handled at the local
level, in consultation with the Local Internet Community (including
governments), and in accordance with local law.

In light of this, we expect ICANN to respond without delay to
notifications of changes to the information in the IANA database
submitted by registry managers provided they pass the necessary
technical checks. Such checks should follow a clear and transparent
process according to objective, publicly available, solely technical
(not political) criteria.

The Internet's value is created by the participation and cooperation of
people all over the world.
All Internet users rely on the efficient functioning of the root
database. Our experience supports the U.N. Secretary General's statement
that the "United States government has exercised its oversight
responsibilities fairly and honourably".

Nevertheless, we wholly endorse article 63 of the Tunis Agenda for the
Information Society in that "countries should not be involved in
decisions regarding another country's country-code Top Level Domain".

Therefore, we suggest that, as the US reviews its contract with ICANN,
it should work cooperatively with all stakeholders on the transition to
a Domain Name System that is free of unilateral governmental control and
based on self-regulation and multi-stakeholder participation. It should
thereby be assured that mechanisms are in place to assure that policies
are both set and implemented in an appropriate manner and that enhanced
cooperation does not further politicise an essentially technical
function and/or lead to increased bureaucracy and costs.

Yours sincerely,

Roelof Meijer
CEO SIDN