From: Dmitry Kohmanyuk <dk@farm.org>
To: <DNSTransition@ntia.doc.gov>
Date: Sat, Jul 8, 2006 12:44 AM
Subject: comment on DNS Transition

in responce to question:

6. What methods and/or processes should be considered to encourage greater efficiency and responsiveness to governments and ccTLD managers in processing root management requests to address public policy and sovereignty concerns? Please keep in mind the need to preserve the security and stability of the Internet DNS and the goal of decision-making at the local level. Are there new technology tools available that could improve this process, such as automation of request processing?

I say:

I beleive that government control of independent organisation from private sector is the right way to structure IANA DNS function. I also beleive that IANA function should be performed with up-to-day technical standards, with staff reachable 24/7 and clear escalation path in case of urgency or emergency. I also think that body performing IANA function (ICANN now) should be more transparent and accountable to the public, at least on level of U.S. public companies or non-profit organisations.

As one of ccTLD managers (.UA top-level domain, Ukraine) I have contacted IANA staff several times to perform changes related to this domain, namely: technical changes (server names and addresses), contact information changes (address/phone numbers) and administrative requests (change of persons and organizations registered in IANA database.)

Technical changes are implemented correctly, but rather slowly (5 business days minimum); there is no clear status reporting (on-line or email) about exact stage of process and, most important, no sufficient security (encryption, digital signature) in such communication: how would IANA know who is requesting changes, and how would we know who is talking back to us, without possibility of forgery? All these areas should be worked on to make IANA function perform like best Internet companies do it.

Contact information changes were sometimes not performed at all, even though such information is very important for users of ccTLD to have access to. Even as of know, we still have 5-year old mailing address listed. IANA should work with ccTLDs like a company does with their customers.

On admininistrative requests, such as contact persons and organizations, there seen to be no process at all. Requests from existing managers were delayed in processing, whereus third-party requests were given several considerations, including re-opening resolved request of re-delegation, with no communication to existing ccTLD managers about board decisions which ultimately affe3ct operation of domain name system for .UA (Ukraine) ccTLD. In such case, ccTLDs should have clear communication channel with
escalation path up to the management of the company involved (ICANN presently) and it should be two-way.

I think U.S. government should seriously re-cosider policies that ICANN uses to govern Internet functions, and clearly state boundaries of authority, service guarantees, accountability process, and funding sources that ICANN may use, as a condition of MoU renewal (and perhaps contract extension.) I therefore think that ICANN should be given another chance with clear rules set by third party with no vested interest, in consideration with entire Internet community. Therefore, U.N. role can be advisory, but existing U.S. government authority should be used in full force to assess anf guide ICANN performance.

--Dmitry
.UA administrative contact, dk(at)farm.org