InternetNZ's contribution is in support of the contribution from the Internet Governance Project (IGP) entitled "Roadmap for globalizing IANA: Four principles and a proposal for reform". The IGP contribution sets out four principles to guide IANA contract reform, which InternetNZ supports. These principles mirror the conclusions we have reached independently and have practised in our management of the .nz ccTLD. The model proposed by the IGP, particularly for the establishment of a new body, the DNS Authority, is one that we support in principle, though further refinement of the model is necessary. The contribution offers qualifications and points of detail for consideration in the discussion of this model.
Internet New Zealand (Inc)
Content Contribution to NetMundial
Roadmap for the Further Evolution of the Internet Governance ecosystem
Internationalisation of the IANA Function
7 March 2014 Public Version (there is no confidential version)
For further information, please contact:
Jordan Carter <email@example.com> InternetNZ
Jay Daley <firstname.lastname@example.org> .nz Registry Services
Keith Davidson <email@example.com> InternetNZ
Debbie Monahan <firstname.lastname@example.org> Domain Name Commission
1.1 This submission is from InternetNZ (Internet New Zealand Inc).
1.2 Our vision is of a better world through a better Internet.
1.3 Our mission is to promote the Internet’s benefits and uses, and protect its potential.
1.4 We are a membership based, charitable, not-for profit and non-partisan organisation, working on a wide range of Internet and related telecommunications issues on behalf of the Internet Community in New Zealand – both users and the industry as a whole. We work for New Zealanders on sharing the gains the Internet can bring, for everyone.
1.5 InternetNZ is an At-Large Structure within the ICANN community and is responsible for the administration of the .nz top level domain.
1.6 InternetNZ has two wholly-owned charitable subsidiaries to whom management, operation and regulation of the .nz top level domain are delegated. These are:
1.6.1 .nz Registry Services, the Registry
1.6.2 Domain Name Commission, the Regulator
1.7 InternetNZ has developed a set of principles for TLD administration, in line with which we operate the .nz TLD: https://internetnz.net.nz/TLDPrinciples
2.1 This contribution is in support of the contribution from the Internet Governance Project (IGP) entitled "Roadmap for globalizing IANA: Four principles and a proposal for reform".
2.2 The IGP contribution sets out four principles to guide IANA contract reform, which InternetNZ supports. These principles mirror the conclusions we have reached independently and have practised in our management of the .nz TLD.
2.3 The model proposed by the IGP, particularly for the establishment of a new body, the DNS Authority, is one that we support in principle, though further refinement of the model is necessary.
2.4 We offer qualifications and points of detail for consideration in the discussion of this model in the following sections of this content contribution.
3.1 InternetNZ has long argued for structural separation between the IANA function and ICANN. In our view the separation of the IANA registry function from ICANN's broader policymaking function is in the best interests of TLD managers and of Internet users as a whole. As we noted in our submission to the NTIA:
3.2 Experience within the .nz TLD has shown that functional separation of the registry from the policy development entity, with neither in a position of control over the other, provides significant and necessary safeguards for the customers. These include:
3.2.1 All registry decisions are directly traceable to a publicly available policy document. Any gap in this audit trail is a breach of the contract under which the registry operates and would be expected to lead to contractual sanctions.
3.2.2 The registry can refuse to carry out any request that does not conform to the publicly available policy, without any threat of action against it or any individual as the registry is not contracted to any policy development entity.
3.2.3 Both the registry and the policy development entity are fully developed functions, without the priorities of one limiting the investment and development of the other.
3.3 The approach set out by the IGP is in principle a viable model to achieve this structural separation. Further detail will of course need to be developed.
4.1 The IANA contract is often regarded as the key element to be tackled for ending political oversight of the root. If the strict separation between policy making and operation of the IANA registry that IGP proposes were in place, it would be recognised by all concerned that the real issue is political oversight of the policy making function and not the technical body that implements that policy.
4.2 By the permanent transfer of the IANA contract to the DNSA, as proposed by IGP, the IANA function returns to a purely technical function which no state has oversight of and which requires no political oversight.
4.3 InternetNZ would not support the allocation of the IANA functions to another politically controlled body of any sort. We believe a separation of multi-stakeholder policymaking from technically focused and robust operational entities are the right way to conduct Internet governance.
5.1 For the proposed DNSA, as a purely technical function, the community best placed to manage the service is the TLD community that relies on it absolutely for their own operations.
5.2 The TLD community has an exemplary track record of collaborating on technical matters solely for the public good. A good example is the response to the Conficker worm, which saw almost all TLDs acting quickly, in unison and without payment to block the domain names that were being registered by this worm that threatened to infect a large proportion of home computers.
6.1 The broader reforms aimed at balancing the views of governments, the private sector and civil society and increasing the international engagement in the policy around the 'root' are not problems that are going to be solved quickly. In the proposal from IGP these problems remains but is now rightly restricted to the reform of ICANN, which would set the policy for the root that DNSA would be required to follow.
6.2 The establishment of the DNSA would not in any way reduce the potential scope of the oversight nor does it guarantee disproportionate influence to any one state or other actor. All of the authority remains with the policy function, rooted in the ICANN community.
7.1 InternetNZ supports efforts being made to meet the timetable set out in the IGP paper. This would see the model being detailed and a demonstrable level of support being available by the time that the current IANA contract expires (30 September 2015).
7.2 InternetNZ prefers the ending of political oversight of the root as set out in the model, but if as part of the transition the matter was a bottom line for some stakeholders, we would not be concerned if a limited term extension of the IANA contract between NTIA and the new DNSA was brought into being.
8.1 The IGP proposal rightly separates out technical function of root zone administration from the policy making process, which should be the focus of attention for governments and other stakeholders when considering the future of Internet governance. It also provides a sensible and broadly workable plan for the operation of that technical function.
8.2 For those reasons InternetNZ supports in principle the proposal from the Internet Governance Project.
8.3 We look forward to being part of the conversation in São Paulo as the debate proceeds.
With many thanks for your consideration,