My comments on the EU(UK) proposal after prepcom 3


After prepcom 3 EU(UK) published a paper WSIS-II/PC-3/DT/21-E paper. Here are my comments:


Proposal for addition to Chair’s paper Sub-Com A internet Governance on Paragraph 5 “Follow-up and Possible Arrangements”

  1. In reviewing the adequacy of existing institutional arrangements for Internet Governance and policy debate we agree that adjustments need to be made and we propose accordingly:

  2. Principles The new model for international cooperation stated in paragraph [49] should adhere, besides the Geneva principles, to the following guiding principles:

I note that it says “new model”. The conclusion is that something new is to be created. Something new is to exist at the end of the day.

  • it should not replace existing mechanisms or institutions, but should build on the existing structures of Internet Governance, with a special emphasis on the complementarity between all the actors involved in this process, including governments, the private sector, civil society and international organisations each of them in its field of competence;

This bullet is pretty ok…but…

  • this new public-private co-operation model should contribute to the sustainable stability and robustness of the Internet by addressing appropriately public policy issues related to key elements of Internet Governance;

…note that the previous two bullets together with this create something “interesting”. This says explicitly “…this new public-private…” and this refer to the new system, and not what we have today. Conclusion is that these two (or three) bullets together even more enforce the fact we are looking for something new (instead of ICANN).

  • the role of governments in the new cooperation model should be mainly focused on principle issues of public policy, excluding any involvement in the day-to-day operations;

It is of course ok and fine to say “…involvment in the day-to-day operations”, but how thick will the book be that set the rules for the day-to-day operation?

  • the importance of respecting the architectural principles of the Internet, including the interoperability, openness and the end-to-end principle.

I see this as “sugar”. Irrelevant.

  1. Essential tasks The new cooperation model should include the development and application of globally applicable public policy principles and provide an international government involvement at the level of principles over the following naming, numbering and addressing-related matters:

Ok, here we have some interesting bullets, what the new organisation is to work with:

a. Provision for a global allocation system of IP number blocks, which is equitable and efficient;

This is to remove the IP-address allocation from NRO and the RIR’s to the new org. Very very very bad to even discuss this. My experience say that anything you allow discussions on might be things you loose. I think it is very bad to say anything else than plain “no” on whether IP addresses are to be discussed in the same forum as the domain names.

Compared with domain names, IP addresses REALLY have to do with Internet stability.

b. Procedures for changing the root zone file, specifically for the insertion of new top level domains in the root system and changes of ccTLD managers;

This is what can be fixed by ICANN already today by cleaning up internally.

c. Establishment of contingency plans to ensure the continuity of crucial DNS functions;

What is “cruical DNS functions”? It can of course be ok in some cases to not be precise, but, in this case I think it would be (and is) a very bad idea.

d. Establishment of an arbitration and dispute resolution mechanism based on international law in case of disputes;

What area is this? Disputes according to TLD allocation? Future “sitefinder” incidents? Domain name allocation below the TLD?

e. Rules applicable to DNS system.

What is “DNS system”? Root zone? Protocol? I don’t even think this is english.

  1. Forum function In order to strengthen the global multi-stakeholder cooperation within Internet Governance, we decide to create a Forum. The task of this Forum is to address multidimensional and interrelated public policy issues, through the exchange and sharing of information and good practices. It shall work on the basis of a clear mandate for a predefined period. It should work with existing institutions or organisations and not try to dominate issues already dealt with elsewhere. It should not perform oversight tasks.

Oh, boy…here it says explicitly a Forum is to be created, and I also see ITU rising their hand and say they can do it.

  1. Transition to this new model of international cooperation In order to implement par. 62 to 65, two separate processes will be launched, firstly
  • Creation of the new Forum; and secondly
  • Transition to this new model of international cooperation.

….and this forum is to take care of the transision from ICANN to the new thing that is to be created….

And, by the way, if EU want this forum to be created, and ICANN say no. What is the plan for how to move forward? ICANN is an incorporated in California….