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Dear Stuart,
With great interest we have read your latest report "ICANN - The Case for
Reform".
As we have said numerous times, the RIPE NCC supports the drive to return
to ICANN's core tasks, the coordination of Internet resources on a
technical level. Thus we see a number of promising points in your
proposal.
There are however a number of issues, close to our own mission, that
in the interest of our community and the RIPE NCC members, we feel
we must comment on in more detail.
1. The Policy Making Process in the Addressing Community
With regard to the policy development structure, you state that:
"The current ICANN concept is based on the notion of "bottom-up" policy
development, with the Supporting Organizations responsible for the
development of policy and the Board theoretically just the implementing
device for those policies. In hindsight, the notion of truly "bottom-up"
consensus decision-making simply has not proven workable, [...]".
For the Internet address area, this statement is patently wrong. You must
be aware of the long established, bottom-up processes that the RIRs are
relying on for policy making? These are prime examples of industry self
regulation that have been working for more than a decade now for the RIPE
NCC and for several years for the other RIRs.
You also say:
"Thus, ICANN as it now stands is, at best, an incomplete experiment. In
fact, it is clear to me that, without the steady and committed
participation of all the major operational bodies of the Internet
including essentially all registries and registrars, significant ISPs and
backbone providers, and the major users of the Internet in the development
of necessary policies, coupled with an agreement to abide by those
policies once developed, this particular private sector model will not be
able to fulfill its mission."
It is not clear what the role of these individual organisations would be
with respect to the core tasks of ICANN to co-ordinate resources relevant
for Internet infrastructure on a global level.
On the other hand, all the bodies you mention actively participate in the
regional open forums (i.e. RIPE, ARIN and APNIC meetings), thus forming the
policies they will later have to abide by. It is our conviction that
address allocation policies are best developed "bottom up" by those who
understand the needs of daily operations. Equally we believe that ICANN
should not be a policy developing body, but should, again, focus on
technical coordination.
2. Root Server Coordination and Funding
The so called "volunteers" operating the rootserver system are well funded
and very well co-ordinated. Binding them contractually to one entity,
ICANN, would create a single point of failure, possibly subject to
capture. The current form of organisation works well, and is resistant to
capture through the multitude of different operators and organisations
housing and operating the servers. This system has been stable for many
years. We think that to change it in the way you envision would introduce
risks more important than any co-ordination benefits.
Furthermore, we feel that you would do better not to burden ICANN with the
task of financing the Root Server operating system. Rather, ICANN should
stick to the core mission of coordinating them.
3. Sources and Levels of ICANN Funding
Our experience shows that funding by governments and other third parties
often brings disadvantages for the organisation receiving the funds, as
there are usually direct or indirect strings attached. Funding should be
provided by those using ICANN's services. The RIPE NCC for instance never
relied on external contributions, but was always funded by its members. We
would advise to concentrate on ICANNs original core tasks, to make sure an
'Activity Plan' (or whatever you want to call it) and the budget are fully
transparent and well understood. We are convinced that money from the
beneficiaries ICANN serves will then be forthcoming.
This method is how we assure our own finances. We have discussed this with
you during many budget group meetings: We are ready to pay, even more than
what has been allotted to us today, if we can clearly see the benefit to
our community.
Finally, let us say that we are quite surprised by the way this proposal
was published. The document contains proposals for change of such
fundamental scope, in a field that is of utmost importance to our
community, that we wish that you had discussed these with us beforehand.
After all, we are still discussing the contract documents with you that we
expected would contribute to ICANNs stability. Seeing that you are
proposing fundamental changes to ICANN and the principles behind the ICANN
- RIR MoU, signed in 1999, we believe that in the interest of our members,
we have to thoroughly reassess our relationship with ICANN.
We are looking forward to discussing these issues with you at the earliest
possible opportunity.
Kind regards,
Axel Pawlik
Managing Director, RIPE NCC