From: Chris Wellens <chrisw@iwl.com>
To: NTIA.NTIAHQ(dnspolicy)
Date: 10/13/98 1:32am
Subject: Comments on New Domain Name Corporation
Unquestionably the best ideas for this proposal are from the
Boston Working Group. This Group has carefully thought through
the issues of oversight and accountability that are missing from
the IANA proposal. I strongly support this effort.
Chris Wellens
President & CEO
InterWorking Labs
From: Daniel Karrenberg <Daniel.Karrenberg@ripe.net>
To: NTIA.NTIAHQ(dnspolicy)
Date: 10/12/98 11:34am
Subject: Joint Statement of the Regional Internet Address Registries
Regional Internet Registries Statement on the New IANA
Monday, October 12th 1998
In June 1998, the Executive Boards and Councils of each of the current
Regional Internet Registries (APNIC, ARIN and RIPE NCC) reviewed the US
Government White Paper at
http://www.ntia.doc.gov/ntiahome/domainname/6_5_98dns.htm and welcomed
it, especially the emphasis on self-administration for the Internet.
In particular, the registries believed then and believe now that for
stability of operation, the technical work of the new IANA corporation
must be initially built out from the existing IANA technical team hosted
by the Information Sciences Institute of the University of Southern
California.
The three Regional Internet Registries have supported and participated
in the various processes helping to build consensus about the
incorporation of the new IANA. In particular we have commented publicly
on recent drafts published by the current IANA and have seen many of our
concerns addressed in the process.
We fully support IANA's proposal as submitted to the NTIA on October 2nd
and commit to work within its framework. While this framework is not
perfect from all points of view, we realise that any result of a global
consensus building process cannot be perfect for any one party. We are
confident that the IANA proposal is good enough for the present and that
it has the potential to evolve further as necessary.
We commit to work together and with others to establish the "Address
Supporting Organisation" and have it recognised by the new IANA as soon
as practical.
We renew our commitments to contribute our fair share of the operational
costs of the new IANA.
---
The Asia Pacific Network Information Centre (APNIC)
APNIC, the Asia Pacific Network Information Centre, performs Internet
address allocation and registration, and other Internet administration
services, throughout the Asia-Pacific region. It is one of only three
such organisations which exist in the world today, and which are
officially recognised and empowered by the peak administrative body of
the Internet, the Internet Assigned Numbers Authority (IANA).
APNIC is an open, neutral, non-profit and membership-based organisation.
It has over 220 members located in over 40 countries and regions, as
well as more than 200 organisations represented by APNIC Confederations,
throughout the Asia-Pacific. Most APNIC members are Internet Service
Providers (ISPs), National Network Information Centres (NICs), or
multinational organisations.
For more information about the APNIC see http://www.apnic.net/
----
American Registry for Internet Numbers (ARIN)
ARIN is a not for profit, membership-based organization tasked with
the administration and allocation of Internet addresses and
Autonomous System numbers for North and South America, Carribean and
sub-Sahara Africa. ARIN has been in operation since December 22, 1997
and currently has 180 members. To date, ARIN has allocated IP numbers
and/or ASNs to approximately 900 organizations.
For more information on ARIN see http://www.arin.net/
---
Reseaux IP Europeens Network Coordination Centre (RIPE NCC)
The RIPE NCC provides Internet address space registration and other
coordination services in the RIPE area which includes Europe, northern
Africa, the Middle East and parts of northern Asia. The structures and
activities of the RIPE NCC have been developed through open processes
starting from initial proposals in 1990, becoming operational in 1992
and incorporating as a not-for-profit association funded by its members
in 1997. The RIPE NCC association currently has more than 1100 members
from 88 countries, most of them Internet service providers. The RIPE
NCC members provide Internet service to millions of users in more than
100 countries. The NCC staff is based in Amsterdam and the budgeted
operating expenditure for 1998 is 3457 kECU.
For more information about the RIPE NCC see http://www.ripe.net/
CC: NTIADC40.SMTP40("comments@iana.org")
From: "David W. Maher" <dwmaher@ibm.net>
To: NTIA.NTIAHQ(dnspolicy)
Date: 10/12/98 12:45pm
Subject: Comments by POLICY OVERSIGHT COMMITTEE on Private Sector Proposal for New Domain Name Corp.
Honorable William M. Daley
Secretary of Commerce
c/o Karen Rose
Office of International Affairs
Room 471
National Telecommunications and
Information Administration
United States Department of Commerce
14th and Constitution Avenue, N.W.
Washington, D.C. 20230
Re:Management of Internet Names and Addresses
Dear Secretary Daley:
On October 2, 1998, Professor Jon Postel wrote to you regarding the
Articles of Incorporation and proposed bylaws for a new corporation that
has been formed in response to the "White Paper," in which NTIA called
on private sector Internet stakeholders to form a not-for-profit
corporation to administer policy for the Internet name and address
system. The Policy Oversight Committee (POC) fully endorses the
proposal by Professor Postel, and agrees with his conclusion that the
"documents reflect the consensus judgment of the global Internet
community as to how to form a corporation that will include the IANA
function, and in addition take on other coordination and administrative
responsibilities necessary for the continued operational stability and
growth of the Internet." The POC urges you to accept Professor Postel's
proposal and take the necessary steps to transition the United States
government's role in Internet administration to the new corporation.
The POC is an international committee and is the successor to the
International Ad Hoc Committee ("IAHC"), which was formed and chartered
by the Internet Assigned Numbers Authority ("IANA") and the Internet
Society ("ISOC") to take a leading role in the evolutionary growth and
development of a program for expansion of the
generic Top Level Domain name system. The present members of the POC are
listed in the Committee's web site at http://www.gtld-mou.org/.
The POC has been an active contributor to the restructuring of the
new IANA, and believes that the consensus views developed in several
recent related meetings are suitably reflected in Professor Postel's
proposal.
The POC is aware that some other stakeholders in the process have
expressed concerns about Professor Postel's proposal. The POC believes,
however, that the proposal offers sufficient protection for the public
interest and sufficient flexibility to deal with some of the hypothetical
problems envisaged by others to merit full support now. With its high
profile internationally, the new corporation will be constantly under
scrutiny by all the stakeholders and the POC believes that it will take
their views into account. Further delay can only compound the
uncertainties for the industry.
The POC believes that the proposal defines the basic framework
for an institution which will provide stability, transparency, a balance
of representation of legitimate interests of stakeholders, yet still
providing for innovation and further evolution of the Internet, as more
fully explained in Professor Postel's letter of October 2.
Respectfully submitted
Policy Oversight Committee
October 12th 1998
To: NTIA and Secretary Mr. Daley
From: Several ISP-organisations, by way of Alfred Eisner (pres./CEO of NLIP Dutch ISPA)
Subject: ICANN
With regard to the published DNSPOLICY we would like to draw your attention to what we think is a major shortcoming in the rules for and the board of ICANN. This flaw seriously threatens the effect and working conditions of ICANN.
"We" in this case are ISP's almost worldwide. Representatives of ISP-organisations of EU, US, Canada, and others. We met in Ottawa oct. 8th. in the margin of the OECD-conference, and we all expressed our deeply felt worries concerning this matter.
Notwithstanding the fact that a lot of good work has been done to reach some kind of consensus, the result is not completely satisfactory and does in its present form NOT guarantee quality and continuity. The shortcoming we are referring to is the fact that, where the issueing and control of domainnames and ip-addresses is of crucial importance to the correct functioning of the Internet as being delivered to the public by ISP's, there is no direct influence of those ISP's in running and controlling ICANN.
Since ICANN's policy and operational decisions are to be implemented by us (ISP's) in the worldwide DNS's, and are largely to be paid for by us (and indirectly by our customers), this complete lack of say in these matters is unacceptable. And, just for the record: we are not and feel not in any way represented by people from telco's, networkoperators or large computer or software companies. One might even say: on the contrary. They are not ISP's.
To put it more abstractly: Industry-selfregulation without the crucial sector of industry being represented, is a strange idea in itself. It is definitely not industry selfregulation.
We are unable to discover valid reasons which could justify the exclusion of ISP's from direct
representation in the Interim Board (now) and the final board (later). If this oversight is not duly corrected, the conclusion will have to be that the Interim and final Board do not constitute a valid industry self regulation.
To solve this we propose that you allow one more change in the bylaws, leading to the effect that ISP's are directly and adequately represented. Adequately will mean a substantive part of the board. To repair the situation at hand as soon as possible, we ask also that the interim board acts accordingly in their future appointments from the beginning.
With kind regards,
yours truly,
A. Eisner (Netherlands), M. Langford (Canada), M. Schneider (Germany). CIX (USA) is also with us, but will send their reaction separately.
From: Jay Fenello <Jay@Iperdome.com>
To: "dnspolicy@ntia.doc.gov" <dnspolicy@ntia.doc.gov>
Date: 10/12/98 1:55am
Subject: Stay tuned, we should know shortly . . .
The more things change . . .
. . . the more they stay the same !
From: Jay@Iperdome.com
Date: Tue, 18 Nov 1997 13:58:34 -0500
To: com-priv@lists.psi.com
Subject: EEKs, SIPs, and the DNS
Cc: DOMAIN-POLICY@LISTS.INTERNIC.NET, gtld-discuss@gtld-mou.org
It's been a couple of weeks since it happened . . . that's when
I saw a presentation by Dr. Grove (Chairman and CEO of Intel)
to a meeting of the Economic Club of Detroit. While I already
understood the concept of Strategic Inflection Points (SIPs),
I was about to gain some insight into the current battle
regarding the Domain Name System (DNS).
Over the last many months, a huge battle has been raging
over the very future of the Internet. It has been cloaked
in discussions about domain names, but the implications for
the decisions that are about to be made are far reaching
and long lasting.
According to recent press reports, November is the month
that these issues may finally be resolved. That's when the
Commerce Department is expected to issue their recommendations
on how to transition the administration of the Internet to the
private sector.
My involvement started back in January, an eternity ago in
Internet time. That's when I started Iperdome, a company
formed to offer Personal Domain Name services under the
.per(sm) name and Top Level Domain. My idea was to provide
Netizens with a permanent address on the Internet, one that
does not change when they change jobs, schools, Internet
Service Providers (ISPs), or email addresses.
Almost immediately after I started, a group known as the
Internet Ad Hoc Committee (IAHC) put forward their "final
draft" proposal for expanding the name space. While their
plan had some nice features, there were many problems with
their proposal:
- they wanted to assume authority over the name space,
- they wanted to confiscate existing properties like .com,
.web, and .arts,
- they wanted to prevent the implementation of other
solutions like .per(sm),
all while they had no authority to make these decisions in
the first place.
Since that time, the battle has been raging. On one side of
this debate are entrepreneurial companies, trade organizations,
governments, and Network Solutions, the current registrar for
.com, .net, and .org.
On the other, a small group composed of the Internet old guard,
and some regulatory agencies of the United Nations. Collectively,
they go under an assortment of names like gTLD-MoU/POC/PAB/CORE/etc.
Their goal is to preserve their long-term status on the Internet.
In the middle is the U.S. Government. They have been responsible
for much of the infrastructure that the Internet is built upon,
and for funding many of the administrative tasks that are required
to keep it functioning properly.
While it is clear that all sides in this issue have their self
interests at play -- that's to be expected -- there is something
different about this debate. Specifically, the resolution to this
battle will have profound and long lasting implications for the
future of the Internet:
- Who will govern the Internet?
- Who will have a say in this governance?
- Will there be any kind of due process?
- What business model will be supported?
(competitive or bureaucratic)?
This is a classic Strategic Inflection Point, not only for the
factions named above, but for the entity we collectively call the
Internet. That's because this change will be so powerful that it
will fundamentally change the structure, control and function of
the Internet. And because the Internet has the potential to
profoundly change our global society, these decisions will
also change our collective future.
While I believe this to be true, it is often difficult to predict
when you are in the middle of SIP. But in this case, it is pretty
obvious: it matches the definition of an SIP, and it displays the
three warning signs as described by Dr. Grove in his speech.
The third warning sign is particularly insightful. It describes
how people start fighting vehemently, how they no longer understand
one another, and how they appear to be "losing it" all around. And
it is a perfect description of our current situation.
I have often wondered how my beliefs about the DNS could be
so far off from members of the Internet old guard. This was
especially true when I met them one on one, or exchanged private
email with them. As rational as they seemed, we were still 180
degrees apart on the DNS issue.
Recent revelations show that even within our own government,
there is some disagreement about what should be done. Thanks
to Dr. Grove, we can all appreciate that this is to be expected,
given the implications of the decisions we are about to make.
With so much at stake, it is also easy to understand how someone
like Eugene Kashpureff (EEK) could be so passionate in his beliefs
that he deliberately took some actions that were sure to draw
attention to this debate. Today he sits in a Canadian jail where
he will remain until the first week in December, at the earliest.
[While I don't condone what Eugene has done, I don't believe that
his actions warrant this kind of treatment!]
As we all anxiously await the U.S. Government's announcement,
there are some encouraging signs. A few weeks ago, one of the
IAHC organizations held a press conference where they backed off
of their claims to ownership over the entire DNS system. They
also backed off of their claims to .com.
In addition, last week Mr. Magaziner got involved in the DNS
fracas. He reportedly said "there are lots of discussions
going on among lots people both inside and outside of government.
There is a lot more discussion and consultation that has to take
place before any decisions are made."
So, that brings us up-to-date. Will the Internet be saved from
a despotic future? Will the registries that were in this business
first be treated fairly? Will the U.S. Government transfer the
administration of the Internet to a small group that is
accountable to no-one?
Stay tuned, we should know shortly . . .
Copyright (c) 1997 Jay Fenello -- All rights reserved
Regards,
Jay Fenello
President, Iperdome, Inc.
404-250-3242 http://www.iperdome.com
CC: NTIADC40.SMTP40("list@ifwp.org","Ira_C._Magaziner@...
From: <laina@singnet.com.sg>
To: NTIA.NTIAHQ(dnspolicy)
Date: 10/12/98 7:16pm
Subject: Comments regarding the various proposals
Submission by Laina Raveendran Greene, as her personal opinion.
(Managing Director of GetIT Pte Ltd, Chair of APPLe, Advisory
Panel member of APIA, International Advisory member of PECC
Telecom Forum, Panel of Experts member of WIPO Process)
*TRULY AN OPEN PROCESS OR NOT?- THAT IS THE REAL QUESTION.*
I would like to acknowledge the US Department of Commerce for
its open process, since July 1997 regarding this issue. The
opportunity to comment on such a significant issue is much
appreciated. I certainly hope, that by putting all four
proposals on your web site, indicates that the Department of
Commerce does not pre-judge the application of one over the
other. All have their merits, and its their key elements, and
not the totality of their format that should be reviewed.
However, there is concern, based on feedback of recent events
in the US, regarding the weightage you may give to comments
coming from outside of the United States. Of late, your actions
to take consultations behind closed doors have been of great
concern.
The International Forum for the White Paper process, which you
seemingly supported, seems to have been sidelined and stronger
US lobbying interests seem to have taken precedent. While it is
recognised that you are accountable only to your domestic
constituents, since this is a global issue, the US government
should act on behalf of the good of the global Internet
community, not only the US commercial community.
If your actions tend to support only US commercial concerns,
then I tend to agree with the comments of Ronda Haueben that
these kinds of functions should be held on public trust and not
run as commercial activities. However in such as case I would
prefer to see the involvement of an inter-governmental
organisation, over the US government alone. That is not to say,
I support this as THE solution, but that it would be preferable
to handing over the resources of the global Internet to a
select group of individuals and entities to control and manage
for monetary gains, etc.
There are many of us, especially from the international
community, who believed in your support of the IFWP process and
incurred great expense and time to follow the various
international consultation on the matter. Yet the recent turn
of events, is VERY disappointing. For example,I am troubled by
the fact that you have not included a more representative slate
of Interim Board members, and have no Latin American
representative as well. Or for that matter, there is slate of
candidates that have not gone through some level of public
review.
*WEAKNESSES OF THE WHITE PAPER WHICH MERELY CAUSED MUCH OF THE
PROBLEMS*
You had from March 1998 to make these pronouncements, and yet
you waited till June 5th to make the pronouncements and then
gave industry only the summer to come up with solutions.
Imagine how many of us had to make changes to our summer plans
and to support you in the attempt to do global industry
self-regulation. It now appears to be a un sincere attempt to
get true global participation, but rather to use the process to
support any proposals you may choose to adopt. Rather than
give industry more time, and ensure global input, you seem to
have opted in favour of US Congressional Hearings and closed
door negotiations. All this is VERY disturbing indeed.
The White Paper was weak in that it merely pronounced that
private sector was going to create the new entity. Who this
private sector was, how they were to form this entity, how you
would recognise the entity etc were never stated. This left a
black hole, and since the announcement of the White Paper, many
entities began the self-proclaim themselves as part of this
effort, and announced meetings. That is why, it was very
reassuring to have the IFWP process as a means to coordinate
these various efforts, and the US government, IANA, NSI's
seeming support of this process, made people rally their effort
behind it at their own expense. It was only after it became
clear that perhaps NSI and IANA with the US government were the
real players, that the IFWP process broke down and people began
positioning themselves. I am glad that there is at least some
proposals on the table from people who have been involved in
that process.
By not having a clear procedure in place, you have actually
given it the opposite effect of lack of due process, not to
mention wasting everyone else's time and money. I do hope the
US government will take cognisance of their own mistakes, and
give industry a little more time to solve the issues. I am not
suggesting that we wait until we have the ideal solution, but
that there should be a little more time, and some clearer
indication on what would be accepted and by whom. Even now, it
is unclear what the impact of the other proposals would be,
given that there has been clear and open support for the ICANN
proposal by the UD Department of Commerce during the
Congressional Hearings.
It would have been preferable to have some of these proposals
on the table, while the IFWP process was going on, rather than
leaving everything now to online discussions without a clear
mandate, indication of what will be done with the comments,
etc. I almost feel that I would be wasting my time again, which
is why I declined to give detailed comments as I have done in
the past. Given also great government involvement in amny
spheres of economic activity, it is important that their input
also be sought and the relevant UN agencies such as UNDP/APDIP
for the Asia Pacific region be used to ensure government
awareness and endorsements.
*SOME BRIEF COMMENTS REGARDING THE VARIOUS PROPOSALS*
INTERIM BOARD-
While I tend to agree that it is hard to come up with a slate
of people that EVERYONe agrees with, it would have been better
to have some procedure of endorsing these candidates or having
other candidates proposed as well, through a more open fashion.
This way, we can ensure greater trust in the Board by the
greater Internet community. Without this trust, there will be
greater hesitations to their scope of duties and decisions, and
we can expect more litigation if there are outcomes people do
not like.
BOARD-
Both the Interim Board and Board should have some mechanism of
being vetted by the Internet community at large, since they are
after all custodians of a global Internet resource. There
should also be some accountability and transparency mechanism
to the greater Internet community (membership or otherwise)
If the Board does not seem representative nor are there clear
accountability measures, then I will have even greater problem
with them being nominated by the Supporting Organisations for
future Boards. It will become self-perpetuating Boards
(especially since according to the Bylaws of ICANN aRT 5
SECTION 9, the Board elects themselves at the Annual Meeting of
the Board).
It becomes easy for the Supporting Organisations therefore to
be more than just advisory entities, since now they can stack
up the Board and ensure that their policies get rubber-stamped.
Where then are the people who protect the interests of the
greater Internet community?
In other words, the Board should be elected by at-large
community, with or without a membership structure.
Meanwhile, the deletion of the President as a member of the
Board, is also support (see Boston Working Group draft). The
President should be allowed to attend the meetings (provided
Board approval is given) and advise the Board, but should not
be counted in as a member nor should have voting rights. This
will ensure greater accountability to the Board, without the
right to influence the decisions. It would seem strange that as
officer of the Corporation, the President for example, can vote
and decide on his own salary.
ACCOUNTABILITY-
There should be as open an accountability as possible. Section
2, Art 3 of the ICANN draft for example, excludes disclosure of
reimbursements of expenses. This should be deleted. (see
improvements made in Boston Working Group Draft)
Section 2 also allows the Corporation not to disclose matters
if it contravenes a contract. This is not acceptable, since it
would be easy for the Corporation to enter into a contract and
put it into the provisions to prohibit disclosure, thereby
concealing its affairs. (see improvements in Boston Working
Group draft)
The Boston Working draft also has provision for appeals (Art 5,
section26), and for the case of conflict of interest,
declaration of such interest not just to the Board but for
public record as well (Art 5, section 7).
The Boston Working Draft also includes the concept of having an
open annual business plan. This could be another idea to ensure
some level of accountability and efficiency. This is provided
both in art 5 section 25)
ADDITIONAL QUALIFICATIONS- ART 5- SECTION 5 OF ICANN
While I can see the rational behind excluding government
participation, exceptions should be made for entities wholly
owned by the government. This is the case for some national
NICs, which are run by a private entity wholly owned by the
government. This is the culture of much of the Asia Pacific
region, for example, and ruling these individuals out would
limit the participation of some individuals from the region.
These people are not civil servants as such, but rather
accountable to the Board and run the entity just as any other
commercial entity does.
Some room for exceptions should be made, or the definition
should be narrowed to national, regional or international civil
servants.
INTERNATIONAL REPRESENTATION- ARTICLE 5-SECTION 6 OF ICANN
I am also disturbed by the limitation of participation to
residents of a region, rather than nationals of a region. If it
applies to residents, this could still mean that nationals of a
country or region, dominate the Board just because they live
around the world. Likewise, there could be a good candidate,
national of a region that is disqualified just because he is
living in a region that already has 1/2 Directors on the Board.
BTW, Australia is a country not a region. It should read
Australasia and not Australia.
MEMBERSHIP ISSUE
While I see some value of having the membership defined and
election process clarified in the ORSC proposal, I have no
clear views either way. If there are mechanisms to get some
accountability and elected Board from the Internet community as
a whole, then there may be no need for members as such. On the
other hand, if the at-large community is hard to define and
reach out too, then membership may be the way. More thought
needs to be put into this, to ensure that we do not have a
membership structure that also allows for capture by a small
minority.
Here are some quick observations, and I would like to end by
quoting the White Paper. I sincerely hope that the US
Government will practice the words it uses in the White Paper,
to ensure
Stability- should not disrupt current operations or create
competing root systems
Competition- market mechanisms that support competition and
consumer choice
Private bottom-Up coordination- private sector action is
preferable to government control
Representation- should have functional and geographic diversity
in its decision making
Please do not give this lip service. YOu are talking about
resources which affect the whole global Internet community, and
it is your responsibility to carry this function responsibly, I
do hope you will consider giving the process a little more
time, for general endorsements, inputs etc. Please do not rush
into unnecessary decisions, which will only backfire and not
provide stability. Please ensure true global participation and
input into the process.
Regards,
Laina Raveendran Greene
-------------------------------------
Name: Laina Raveendran Greene
E-mail: laina@singnet.com.sg
Date: 12/10/98
Time: 19:16:12
This message was sent by Chameleon
-------------------------------------
From: Werner Staub <werner@axone.ch>
To: NTIA.NTIAHQ(dnspolicy)
Date: 10/12/98 10:01am
Subject: Support for ICANN proposal
To whom it may concern:
Axone Services & Développement SA wishes to state its support
for the ICANN proposal submitted to NTIA by IANA.
While there are many issues - such as balanced international
representation - remaining to be addressed, we feel that they
cannot be resolved in a process centered around the US government.
The incorporation of ICANN without further delays is the only
workable basis for the international consensus building process
from now on.
Non-US stakeholders find it intolerable that the future of the
Internet primarily should depend on political lobbying in the US.
We are particularly concerned about well-funded lobbying campaign
by NSI, the beneficiary of the current gTLD monopoly, to further
delay the introduction of competition.
We are equally concerned about the de facto extension of NSI's
monopoly along with the imposition upon the Internet community
of technical instruments (such as a proprietary protocol) likely
to consolidate and to perpetuate NSI's stranglehold in the long
term.
Our company (http://axone.ch) is a signatory of the gTLD-MoU and
a member of CORE. It has actively participated in the meetings and
discussions on new top-level domains, including the PAB (Policy
Advisor Body), CORE, the EC Panel of Participants and the IFWP.
Yours truly,
Werner Staub