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ISPA UK statement on Management of Internet Names and Addresses

13 October 1998

Honorable William M Daley
Secretary of Commerce
c/o Karen Rose
Office of International Affairs
National Telecommunications and Information Administration
United States Department of Commerce
14th and Constitution Avenue, NW
Washington DC 20230

Dear Secretary Daley,

The United Kingdom Internet Services Providers Association (ISPA UK,
http://www.ispa.org.uk) is a trade association representing Internet 
Service Providers providing most of the Internet connectivity in the 
UK.  ISPA UK is a member of EuroISPA (http://www.euroispa.org), the 
pan-European federation of Internet trade associations.

On behalf of ISPA UK I would like to express our support of the
recently-submitted statement of Dr Alfred Eisner of NLIP, the Dutch
Internet trade association, regarding shortcomings in the structure
of the Internet Corporation for Names and Numbers.  A copy of Dr 
Eisner's statement is attached.  Please note that it is also endorsed 
by eco, the German Internet trade association (http://www.eco.de).

In a letter to you on 2 October Dr Jon Postel of IANA proposed that
ICANN assume responsibility for the management of Internet names and 
numbers, in effect subsuming IANA's existing role in this regard. 
That is, ICANN is to become the "new corporation" of the recent 
White Paper on this subject.  

The objective of this new corporation is the self-regulation of the
Internet industry.  It is therefore surprising to us and a matter of
great concern that the Internet industry has not been consulted in 
regard to the selection of the Initial Board for ICANN, nor do its
articles and bylaws give the world's ISPs any particular voice in
its management.  In light of the fact that we are the industry being
"self"-regulated, in light of the fact that there are at least 
proposals that the ISPs should fund the new corporation, and in 
light of the fact that industry cooperation is essential to the
new corporation's success, this is inexplicable.

While the rapid pace of developments in this area have made it 
impossible for the EuroISPA council to meet to formally ratify 
Dr Eisner's statement, we know that other ISPs across Europe feel
the same misgivings about the lack of ISP representation in the
management of the new corporation.  In fact we know of no ISP
association anywhere in the world that supports it.

We do not wish to delay the transition to the new system for
global management of Internet names and numbers.  We believe that it
is vital that IANA's role in this be maintained.  However, we also 
believe that it is essential for the success of this exercise in 
industry self-regulation that representatives of the industry being 
regulated have a significant voice in it.  Without the participation 
and the endorsement of the ISPs, it cannot succeed.

To this end we propose that the NTIA delay acceptance of the IANA/ICANN
proposal until such time as they agree to negotiate in good faith with
representives of the global Internet industry, with the object of that
negotiation being a voice for industry in its self-regulation.

Yours sincerely,

Jim Dixon                                                 Managing Director
VBCnet GB Ltd                http://www.vbc.net        tel +44 117 929 1316
Member of Council                               Telecommunications Director
Internet Services Providers Association                       EuroISPA EEIG
http://www.ispa.org.uk                              http://www.euroispa.org
tel +44 171 976 0679                                    tel +32 2 503 22 65

------------------------ STATEMENT OF ALFRED EISNER -----------------------

October 12th 1998

To: NTIA and Secretary Mr. Daley
From: Several ISP-organisations, by way of Alfred Eisner (pres./CEO of NLIP
Dutch ISPA)
Subject: ICANN

With regard to the published DNSPOLICY we would like to draw your attention
to what we think is a major shortcoming in the rules for and the board of
ICANN. This flaw seriously threatens the effect and working conditions of ICANN.

"We" in this case are ISP's almost worldwide. Representatives of
ISP-organisations of EU, US, Canada, and others. We met in Ottawa oct. 8th.
in the margin of the OECD-conference, and we all expressed our deeply felt
worries concerning this matter.

Notwithstanding the fact that a lot of good work has been done to reach some
kind of consen sus, the result is not completely satisfactory and does in
its present form NOT guarantee quality and continuity. The shortcoming we
are referring to is the fact that, where the issueing and control of
domainnames and ip-addresses is of crucial importance to the correct functio
ning of the Internet as being delivered to the public by ISP's, there is no
direct influence of those ISP's in running and controlling ICANN.

Since ICANN's policy and operational decisions are to be implemented by us
(ISP's) in the worldwide DNS's, and are largely to be paid for by us (and
indirectly by our customers), this complete lack of say in these matters is
unacceptable. And, just for the record: we are not and feel not in any way
represented by people from telco's, networkoperators or large computer or
software companies. One might even say: on the contrary. They are not ISP's.

To put it more abstractly: Industry-selfregulation without the crucial
sector of industry being represented, is a strange idea in itself. It is
definitely not industry selfregulation.

We are unable to discover valid reasons which could justify the exclusion of
ISP's from direct  
representation in the Interim Board (now) and the final board (later). If
this oversight is not duly corrected, the conclusion will have to be that
the Interim and final Board do not constitute a valid industry self regulation.

To solve this we propose that you allow one more change in the bylaws,
leading to the effect that ISP's are directly and adequately represented.
Adequately will mean a substantive part of the board. To repair the
situation at hand as soon as possible, we ask also that the interim board
acts accordingly in their future appointments from the beginning.

With kind regards,

yours truly,

A. Eisner (Netherlands), M. Langford (Canada), M. Schneider (Germany). CIX
(USA) is also with us, but will send their reaction separately.

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