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The recent Request for Comments on IANA's contract attracted a substantial amount of comments. Among them were the comments of Jacob B. Odame, participant of the 2011 IGCBP Africa SW. Jacob, from Ghana, is currently pursuing his Master's in Communication Technology and Policy at the Institute of Information and Telecommunications Systems at Ohio University, US.
Jacob's comments centre on the entities that the IANA contract should refer to, and on globalisation as a key element to IANA's operations. The comments can be viewed here: http://www.ntia.doc.gov/comments/110207099-1099-01/comment.cfm?e=AB...
Meanwhile, the 2011 IGCBP Africa SW team also discussed in detail the IANA contract and the six questions that were asked in the Request for Comments. The following is a summary of the points that were raised in class:
1. The IANA functions have been viewed historically as a set of interdependent technical functions and accordingly performed together by a single entity. In light of technology changes and market developments, should the IANA functions continue to be treated as interdependent?
- The IANA functions should continue to be considered as an interdependent technical function performed by a single entity. This is because each of these functions impact directly on the performance of the Internet, as such, the co-ordination required to ensure that these functions are implemented seamlessly would best be done within a single entity for both security and stability concerns.
- IANA functions should be interdependent, especially with regard to some of its technical functions such as the administration of certain responsibilities associated with DNS root zone management.
- All Internet functions should be grouped together and be administered as one. The ‘one’ should know what the other is doing; it’s important to have uniformity at all times.
- Although a single entity co-ordinates the functions, it is still important to have advisors on different fields.
- IANA functions should be interdependent because the functions require specific expertise, developed over decades of technical interaction with the Internet community; therefore there is no advantage to splitting up the different functions.
2. The performance of the IANA functions often relies upon the policies and procedures developed by a variety of entities within the Internet technical community such as the IETF, the RIRs and ccTLD operators. Should the IANA functions contract include references to these entities, the policies they develop and instructions that the contractor follow the policies?
- The IANA functions are generally technical in nature; however, these technical functions are the means by which the Internet operates, and provide the tremendous access to information and communications facilities and services that are reportedly being used by some two billion individuals. These technical functions must be guided by policies and procedures to which the contractor must be accountable. To ensure that the policies and procedures developed to guide IANA in the performance of its functions and appropriately implemented, the responsibility to be bound by them should be done contractually.
- The contract must stipulate the links to different agencies responsible for activities.
- Given the operational culture and open policy-making framework that are definitive attributes of these communities, this action will add a quotient of transparency to the functional administration of IANA.
- The IANA contract should definitely include references to Internet technical community bodies. However these technical communities should portray worldwide support.
3. Cognizant of concerns previously raised by some governments and ccTLD operators and the need to ensure the stability of and security of the DNS, are there changes that could be made to how root zone management requests for ccTLDs are processed?
- Perhaps an improvement to the present system would be the inclusion of the Regional Internet Registries (RIR). The change request from TLD operators could be submitted to the RIR who would conduct preliminary due diligence and forward the request to the IANA Functions Operator which would verify the request and make a recommendation to the Administrator. This would provide a second layer of due diligence and maybe simplify things for the IANA Functions Operator. The RIRs could process requests originating within their respective regions and forward same to the IANA Functions Operator. It may reduce the number of simultaneous requests being processed by the operator.
- IANA operations directly affect the entire Internet; any changes made on how ccTLDs are processed must be done in due diligence with conformity to approved policies and procedures.
- Better stability and security would be accomplished by keeping all of the root-zone signing within the IANA function. The success of signing the root, despite the extra unnecessary degree of difficulty imposed by maintaining previous contractual relationships, shows that IANA is more than capable of doing the complete task. Also, the financial obligations that goes with it is too outrageous and should be taken a close look at.
4. Broad performance metrics and reporting are currently required under the contract. Are the current metrics and reporting requirements sufficient?
On one hand:
-The performance metrics should be maintained and revised on the basis of community standards, not by a contract with an individual government. It appears that the specific details of metrics and reporting have actually been produced through IETF and Internet community interaction, so the only change is getting an unnecessary bureaucracy out of the way. Since the government has expressed its interest in supporting the multi-stakeholder model under which ICANN operates, it presumably already supports this conclusion.
- The reporting should respond to the needs of the community, not conform to the agreement as set in the contract.
On the other:
- The performance metrics based on contract are stronger than those based on community standards, especially so when the implementer may be a private company… Community standards are generally enforced through sanctions, which may or may not change behavior and may or may not be followed. However, legal sanctions and punishments as enshrined in contracts have a more binding effect. Therefore, the performance of IANA should take into consideration the needs of the community of users and ways should be employed as best as possible to capture these need in legal language and placed in a contract.
5. Can process improvements or performance enhancements be made to the IANA functions contract to better reflect the needs of users of the IANA functions to improve the overall customer experience? Should mechanisms be employed to provide formalized user input and/or feedback, outreach and co-ordination with the users of the IANA functions? Is additional information related to the performance and administration of the IANA functions needed in the interest of more transparency?
- The only caution is that the community-based standards should not place an undue burden on the IANA that makes the cost of providing service unbearable. Perhaps the requirement to audit record data for one year and provide an annual audit report to the Contracting Officer and the COTR could be done on a biannual basis. Additionally, the IANA could perhaps establish a consumer desk that would take inputs from the community of users.
- Bodies with specialised expertise in various areas of the IANA functions should be deferred to or given a more pronounced role in the IANA functions. In this way, the processes would be more transparent and the community would feel greater ‘ownership’ of IANA.Feedback from users would really help to improve the performance and co-ordinate things better as an audit trail would be done on a continuous basis preferably annually.
- The contractual oversight should be maintained; what could change is the number of contractual parties with the responsibility to maintain the oversight.
- Contracts should have flexibility in terms of modification and controls. So that large challenge is not left unattended in between the contract periods. Developing countries should be given a place for oversight to promote efficiency.
6. Should additional security considerations and/or enhancements be factored into requirements for the performance of the IANA functions?
- It is very important that developing countries are given room to contribute and become part of the global decision-making process.
- Yes, performance enhancements to ensure safer and more stable ways of meeting the functions of IANA.
- Security considerations and enhancements should be factored in. However this should be done at the minimum level to allow flexibility in implementation of its duties. Something like a general requirement, without the details.