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Request for Comments on the Internet Assigned Numbers Authority (IANA) Functions


Ms. Fiona M. Alexander
Associate Administrator,
Office of International Affairs,
National Telecommunications and Information Administration

Dear Ms. Alexander,

Please be so kind to find the Statement by the At-Large Advisory Committee (ALAC) responding to the set of questions asked in the Department of Commerce's National Telecommunications and Information Administration Notice of Inquiry, Docket number 110207099-1099-01, RIN 0660-XA23, published in the Federal Register, Vol. 76, No. 38, on Friday, February 25, 2011.

On behalf of the ALAC, I thank you for giving us the opportunity to comment on functions as important as IANA's. I remain at your disposal should you need any further explanation on any of our Statement's contents.

Yours sincerely,

Olivier MJ CrÃpin-Leblond, PhD
ALAC Chair

Please see attached file.

(Late Submission)
Verizon's comments we filed on the IANA NOI.

To whom it may concern,

Please find CONAC's response to NOI in the attachment, thank you.


Yang Yu
Director, International Relations
China Organizational Name Administration Center (CONAC)
Jia 31, Guangximen Beili, Xibahe, Chaoyang District,
Beijing 100028
Ph: +86 10 52035167
Fax: +86 10 52035002

Dear Sir, Madam

I am Dwi Elfrida Martina, one of participant of Internet Governance Capacity Building (IGCBP)2011. We would like to submit our comment on IANA functions, as your request. Our comments will be attached in this email (in pdf and word format). Thanks for your cooperation.

Best Regards,

Dwi Elfrida Martina
e-Service Applications officer
Ministry of ICT of Republic of Indonesia Participant of IGCBP 2011

Please find attached the Telecommunication Regulatory Authority of the UAE's, comments in response to NTIA's IANA functions NOI.

May I express my gratitude to the US Government for the manner in which they have overseen the IANA functions contract over the years and thank them for the opportunity of submitting these comments.

Please see the attached document

Paul M Kane

We are participants of the 2011 Internet Governance Capacity Building Programme by Diplo Foundation ( and are pleased to attach our comments on your RFC.


ACP Pacific Class


We, in Rwanda, have not yet managed the repatriate the .RW ccTLD.

Efforts started more than 6 years ago and we were warned by the current operator about the potential lengthy process.

Due to multiple factors, here we are, in 2011, without having succeeded to achieve it.

Though we understand the need to follow a strict process to assure minimal disturbance in service delivery, we believe that the process could be simplified in case the request appears to genuinely satisfy the need of the local community.

We also hope and advocate that should any change occur in the future, it would only simplify the process and not add complexity since we are almost ready in putting all the required building blocks in place based on current specification for TLD re-delegation on the IANA website.

Eddy Kayihura

Kigali, Rwanda

Member of Rwanda ICT Association

Please find attached a submission in response to the IANA Functions NOI from InternetNZ. There are two attachments to this message, both identical, one in MS Word docx format and the other in PDF format.

kind regards

Dear Ms Alexander,

Please find attached CENTR's response on the NTIA's Request for Comments on the IANA Functions.

Kind regards

Wim Degezelle

(Late Submission)
Dear Fiona,

Please accept the following comments in connection with the IANA NOI.

Best regards,


(Late Submission)
Dear Mrs. Alexander,

SIDN is the registry for the .nl country-code top level domain, which, with close to 4.5 million registered domains, is one of the worlds largest and most successful ccTLDs.

We welcome the opportunity to provide comments in response to the National Telecommunications and Information Administrations (NTIAs) Notice of Inquiry on the IANA functions.

Please receive our comments herewith.

Best regards,

Roelof A. Meijer


Attached please find ICANN's comments in response to NTIA's IANA functions NOI. We will also send a hard copy by mail. Please let us know if you have any questions. Thanks

Dear Fiona Alexander,

Please find attached a submission to the IANA NoI from AFNIC, manager of the .fr ccTLD.

Best regards,

Mathieu WEILL
AFNIC - directeur général
Tél: 01 39 30 83 06

Please find attached comments submitted on behalf of ICANNs Internet Service Provider & Connectivity Providers Constituency (ISPCP), to the request for comments on the Internet Assigned Numbers Authority (IANA) functions.

Tony Holmes
Chairman ICANN ISPCPConstituency

Ms. Alexander,

Please find the following attached Adobe Acrobat format (.pdf) comments regarding question #2 of the RFC.


Bartholomew Allerton, retired

Comments of the Internet Governance Project on the NTIA's "Request for Comments on the Internet Assigned Numbers Authority (IANA) Functions" (Docket # 110207099-1099-01)

This submission is from the Internet Governance Project (IGP), an alliance of academics doing research and policy analysis in the fields of global governance, Internet policy, and information and communication technology.

For better or worse, the IANA contract is perceived as one of the linchpins of global internet governance. For that reason, our comments begin by assessing the role of the IANA contract in the overall Internet governance regime.

At the highest level, there are three alternative approaches to the future of the IANA function.
1. One is to continue with the status quo, which involves the U.S. government exercising unilateral control over the nature of the functions embodied in the agreement and choosing the contractor.
2. The second approach, which is desired by many governments around the world, is to multi-lateralize the contracting process. The U.S. would share its authority over the IANA function with other governments, either on a one-country, one-vote basis or through some subset or club of privileged governments.
3. The third approach is to de-nationalize the IANA function. This means fully delegating the IANA functions to nongovernmental actors in the private sector and civil society, and eventually eliminating the U.S. government's direct authority over it.

The first two options have numerous pitfalls. Unilateral U.S. control of the IANA contract disenfranchises most of the world's Internet users, and is a thorn in the side of many other governments, including friendly ones such as the European Union. The U.S. government's role leads inevitably to a demand by other governments for equal status and draws Internet coordination processes into inter-state rivalries, adding an unduly political dimension to activities that should be driven by coordination, efficiency, technical expertise and a concern for global interoperability and the interests of all users. But making the contracting process multilateral and intergovernmental makes a bad situation worse. The involvement of multiple nation-states in basic internet coordination processes would make IANA a plaything of geopolitics and drastically increase the complexity and difficulty of its tasks.

The third approach - de-nationalization - is the best. Denationalization was in fact the original objective of the process that created ICANN. It is worthwhile to reiterate the reason why. It was understood at the time that the Internet needed a truly globalized regime for governing the coordination processes and policies associated with Internet identifiers. Territorial governments insistent upon their sovereign powers were perceived as inherently incapable of delivering that kind of globalized compatibility and coordination. This problem, it was thought in 1997-98, could be avoided through reliance on private sector organizations rooted in the Internet technical community, operating on the basis of transnationally applicable contracts and agreements.

Denationalization, however, requires that the private sector institutions that inherit the governance responsibilities be responsible, accountable and stable. Thus while we agree with ICANN's comments that the IANA contract's ultimate aim should be devolution to a private actor, we do not agree with the implication that ICANN as it currently exists should be the presumptive recipient of all the IANA functions. Part of the reason is the imperfection and lack of maturity of ICANN's accountability arrangements. A more important reason, however, is that ICANN currently combines too many functions in a single organization. Currently, ICANN performs both operational and policy making functions (e.g., running the L root), and the IANA contract unnecessarily concentrates multiple functions in the hands of a single entity. We do not think it advisable to privatize all those functions in a single corporation's hands, especially given the weakness of its accountability arrangements. We see an unbundling of the IANA functions as a way to minimize any risks and dangers that might be associated with de-nationalization. The unbundling must take place first, full de-nationalization second.

We believe therefore that NTIA should use the next cycle of the IANA contract to prepare the way for unbundling the protocol parameters, IP address resources and DNS root zone coordination functions, aiming for the eventual delegation of those separated functions to appropriately accountable non-state actors, such as the IETF for protocol parameters. We recommend that this happen expeditiously, but not too hastily - e.g., over a three-year time span.

With that preamble, we now address the first two questions in the RFC:

Q1: There is no technical or economic imperative that requires combining domain name, IP address and protocol parameter coordination in a single entity. IGP supports the comments of Internet NZ and Bill Manning regarding the feasibility and desirability of separating the distinct IANA functions. Structural separation is not only technically feasible, it has good governance and accountability implications. By decentralizing the functions we undermine the possibility of capture by governmental or private interests and make it more likely that policy implementations are based on consensus and cooperation.

Q2: This is not a simple question. In general, we believe that the IANA contract should avoid rigid, formalized specifications of the roles of specific actors. A U.S. government IANA contract is supposed to be a transitional device on the road to full denationalization. An IANA contract that names specific entities such as ICANN, the RIRs, IETF and ccTLD operators, and then legally requires them to fulfill certain responsibilities with respect to each other, starts to take on the characteristics of a constitution of cyberspace, one that makes the NTIA its perpetual legislator and Supreme Court. We think that is not desirable. On the other hand, we agree with Internet NZ that a well-drafted set of IANA contracts would "clearly state, for each registry, the entity that determines policy for that registry and contain clear instructions that the operator must follow the policy set out by that entity and not create any policy of its own." Ideally there would be separate contracts for each IANA function, and thus no contract would need to reference any entity other than the registry and the policy making entity for that registry.