CNNIC关于NTIA移权方案的评议

On behalf of China Internet Network Information Center (CNNIC), hereby we would like to take this opportunity to make our comments on ICANN’s Draft of Proposal of the Principles and Mechanisms and the Process to Develop a Proposal to Transition NTIA's Stewardship of the IANA Functions. Due to the significant impact of IANA transition to the global internet operation, we support the principle that any decision-making related to the approach and process of IANA transition should embody community consensus and justifiably includes broader interests and concerns of diverse stakeholders. The country code top level domain (ccTLD), as the fundamental actors in the internet stability maintenance at the national or regional level, are crucial stakeholders in the IANA function. To develop a well-fledged proposal of IANA transition, we suggest the design of the IANA transition process should give respect and full consideration to the inputs of each ccTLDs. Therefore, we urge ICANN to extend the public comment period and solicit more input from the ccTLD community. Only in this way can we achieve a consensus-based multi-stakeholder approach to IANA transition.

Our specific comments are as follows:

1 Comment Regarding to the Principles

In addition to the current 10 principles, we would like to reemphasize the importance of “diversity” principle. Especially, we are concerning about the diversity of the steering group members in terms of geography and development level of their origin.

We support the statement in the draft that “care is taken by this (Steering Group) selection process to ensure diversity and regional representation”, so as to prevent the imbalance of regional seat distribution in the Steering Group. In addition to this, we recommend that the assignment of representatives from each region in the steering group should follow an equitable proportional standard regardless of the community each steering group member is representing.

Furthermore, we also would like to stress the importance of having representatives from the developing countries in the steering group, which will further ensure the openness, inclusiveness and global of IANA functions transition policy and decision making process.

2 Comment Regarding to the Mechanisms

Besides the mechanisms mentioned in the draft proposal, we suggest ICANN or IGF to set up various ad hoc platform/fora, where opinions and suggestions from a broader sphere can be brought in and discussed in the ICANN multi-stakeholder ecosystem. In addition, the steering group shall duly publish public comment report and feedback to the community.

3 Comment Regarding to Steering Group Selection　

According to the Draft Proposal, the steering group would be comprised of representatives from each SO (ASO, ccNSO, gNSO) / AC (ALAC, RSAC, SSAC, GAC) group within the ICANN community and the affected parties (IETF, IAB, ISOC, NRO). After community members interested in serving submit a statement of interest, the Chair of the ICANN Board and Chair of the GAC will select the group members from this community similar to the approach used for AoC reviews. Generally speaking, we support the member selection mechanism used in AoC review, which not only guarantees the bottom-up process, but also mind the whole picture to balance and coordinate diversified representations of the steering community. In addition, we suggest that, like the AoC review process, each AC/SO organization shall endorse statement of interest of its member without any filtering. The selection shall be the responsibility of the Chair of the ICANN Board and Chair of the GAC according the standard of geographical and development level diversity.

In addition, regarding to the assignment of steering group member as each SO/AC and affected party has two seats, we are not fully convinced by this absolute average method. ICANN need to explain what kind of theoretical basis or community suggestion has made ICANN think that such allocation merits consideration and discussion. According to the latest data, the count of ccNSO members is almost 150, ccTLD number around the globe is close to 300. With the simple average method in the Steering Group seat allocation, the demands from ccTLD and gTLD communities cannot be represented fully and effectively. On the other hand, In the draft proposal, ICANN recognizes IETF, IAB, ISOC and NRO as “Affected Parties”, and allocated with them around 1/3 seats in the steering group. These organizations are undoubtedly appropriate and important participants in both ICANN’s multistakeholder model and IANA function transition process. However, with only these four as affected parties, the requests and opinions from the multistakeholder ecosystem cannot be represented with equitability and comprehensiveness. The importance of TLD registry operators especially ccTLD community has failed to be properly reflected as well.

4 Comment Regarding to Proposal Development Process

The proposal development process shall guarantee that the diverse opinions and content delivered to the steering group are objectively expressed by the steering group members. Specifically, with the current mechanisms, we are not fully assured of whether the decision-making processes of the steering group members are fully accountable to the community which they are supposed to represent. We suggest that specific guidelines should be set up to keep the impartial performance of the steering group. Filtering of the community input by steering group members should not be acceptable and every input received by a single member must be efficiently forwarded to the entire group for consideration. Furthermore, in the transition proposal drafting process, ICANN shall set up specific mechanisms and guidelines to further guarantee impartial decision-making process of the steering group members.