From: "Chris Disspain" <email@example.com>
Date: Thu, Jul 6, 2006 10:14 AM
Subject: Docket No. 060519136-6136-01 - submission
To The Department of Commerce, US Government,
au Domain Administration Ltd (auDA) is the Manager of .au,
the Australian Country Code Top Level Domain (ccTLD). auDA
is a not for
profit company with members from both the supply and demand
sides of the domain name industry and is endorsed by the Federal
Government of Australia. auDA has a contract with ICANN and
is a member of the Country Code Name Supporting Organisation
auDA makes the following submission to the NTIA Notice of Inquiry.
The DNS White Paper principles are still relevant. It is always
valuable to consider new principles or reconsider the existing
However, it should be noted that operating in accordance with
the articulated principles has led to the advance in Internet
technology and the expanded global reach of the Internet. Further,
care needs to be taken when considering the WSIS discussions.
These are centred on Internet governance generally whereas
this Inquiry relates specifically to the management of the
ICANN has achieved sufficient progress in its tasks, as agreed
in the MOU, for the transition to take place by September 30,
Many of the core tasks and milestones have already been achieved
and significant progress has been made towards the completion
The core tasks and milestones are still relevant. We do not
believe it is appropriate to introduce new or revised tasks.
current tasks and milestones are deemed to have been completed
or achieved to a satisfactory level then transition should
in accordance with the MOU. As to time frame and method, a
transition plan should be prepared by ICANN with input from
We are intimately involved in the ccNSO and believe that significant
progress has been made over the last 2 years in respect to
ccTLD managers participation. The formation of the ccNSO, its
increasing membership, its guidance to ICANN on 'contracts'
managers which has led to the Accountability Framework alternatives
now being entered into all indicate effective involvement in
It appears that the gNSO is also enabling stakeholder groups
to become involved in the ICANN process.
Mechanisms exist in ICANN's structure to deal with improved
involvement. For example, the gNSO is currently going through
Participation can always be expanded and improved. For example,
the current interface between the ccNSO and the Government
Committee needs work to ensure an open dialogue on issues of
relevance to both. The key is to ensure that ICANN and the
supporting organisations and committees recognise the need
for improvement and have mechanisms in place to ensure it happens.
ICANN structure with its ever developing processes and review
mechanisms is equipped to ensure this occurs.
Currently work is being done by IANA on automating the root
management requests as far as possible. This work is being
conjunction with ccTLD managers and with the involvement of
the joint ICANN/ccNSO IANA Working Group. This is the best
achieve greater efficiency and responsiveness whilst at the
same time addressing public policy and sovereignty matters.
It is important to draw a distinction between Internet DNS
management and Internet governance generally. In respect to
DNS, we believe that the current ICANN structure, whilst by
no means perfect, gives the best opportunity to ensure the
stability and integrity of the DNS infrastructure whilst allowing
for a bottom-up processes in a competitive environment.
In respect to Internet governance, we await with interest,
the results of the first Internet Governance Forum and reserve
judgement until we have seen those.
We believe that the time has come for the US Government to
step back from its 'oversight' role and transition from the
MOU so that
the domain name system is independently controlled.
Neither the United Nations nor any body under their auspices
are appropriate bodies to control Internet DNS management.
transparent, bottom up, consensus based model that has been
developed within ICANN over the years is not perfect and is
developing and improving but it is the model best suited to
the task of managing the DNS.
We understand the concerns of many ccTLDs and their governments
about the perceived control of the US Government and the perceived
'US centric' nature of ICANN. We believe that once the US Government
has stepped back and transitioned the Domain Name System to
independent control of ICANN, it will be possible for ICANN
to move swiftly to deal with the 'US centric' perception.
CEO - auDA