Fiona Alexander

Office of International Affairs

National Telecommunications and Information Administration

1401 Constitution Ave, N W

Room 4701

Washington DC

USA                20230





Some personal comments regarding Docket No. 060519136-6136-01


This missive asks for comments in the following seven (paraphrased) areas:


1)      Relevance of DNS White Paper principles.  This are listed in the docket as (stability, competition, coordination, and representation).  All of these principles are relevant, however there is under representation of the principles of self-organization and adaptive agility.  I believe that without due consideration of these principles, Internet users will see a sole-source, zero-cost contract award as “Internet damage” and will “route around it”… e.g. they will take steps to make such choices/awards irrelevant to themselves.


2)      Are milestones being met by ICANN?  From my position as a root server operator, ex-TLD administrator, active in RIR management and occasional contributor to the development of Internet protocol standards, as well as a member of the IANA staff pre 1998, I see sporadic progress by ICANN in meeting the targets set forth.  Pragmatically, ICANN lacks operational capability and has lost much credibility with the technical community in its tenure as the oversight body.  I would strongly encourage ICANN to focus on its core competencies and outsource all operational tasks, if in fact it is successful in executing the proffered contract.


3)      Is the task list still relevant?  Yes, but there are new items for consideration, e.g. integration of PSTN capabilities into core DNS technologies. This brings onboard previously un/under represented communities into the Internet fold.  This is not the only or least of the new technologies, which impact the continuity of operations for a stable Internet.  A private, US-based organization seems ill suited to meet the challenges of integrating these capabilities. In my opinion, direct governmental involvement will reduce the logjam of coordinating with other governments.


4)      Are all stakeholders effectively involved?  Again in my experience the answer is a resounding NO.  In my testimony before Sen. Burns on 30sept2004 there was an expectation that ICANN would re-initiate discussions with the root operators to establish a formal agreement.  No such discussion has occurred to my understanding since then. 


5)      Are the existent committees effective?  In some cases, this may work. Indeed ICANN has spent extensive energy on focusing on the political and business ramifications of the forward DNS tree, constructing processes and business practices that have spawned whole new industries in the management of the DNS name registration activity.  In the areas where there is not a clear-cut case for developing market driven, creation of business opportunities for itself and others, ICANN has been much less successful. 


6)      Are there new processes/methods available?  Yes there are and new ones are emerging.  Several of these tools will support the development of multiple “views” of the Internet name space.  One that I have worked on funded and will be actively promoting support authentication, integrity, and some anonymity as well local character set encoding for ANY zone.  The use of this tool effectively reduces/removes most of the manual overhead for checking, reducing operational costs for any zone administrator.


7)      How can people cooperate?  The easiest way is to use the tools available to them and the Internet has fostered many fine collaborative tools.  What technologies cannot do is ensure that introductions and trust relations are made. These things can be augmented by technologies but there is no replacement for direct human interaction.


Thank you for allowing me the chance to share my thoughts and considerations on this very important step that is being considered.


Bill Manning

PO Box 12317

Marina del Rey, CA

USA    90295