Comments from ARI Registry Services

[Donna Austin <Donna.Austin@xxxxxxxxxxxxxxx>]

ARI Registry Services thanks the CWG for their work undertaken to date on 
developing a proposal to transition the
NTIA oversight and stewardship role as it relates to the IANA function.

We do not seek to provide specific comments on the proposal as we largely 
support the comments provided by the Registry Stakeholder Group. However, we 
would like to provide input in the form of principles that we consider 
important in this exercise. These principles are provided below in no 
particular order of importance.

* The role performed by the IANA Department is largely technical and 
operational. The role performed by the IANA Department should not be conflated 
with ICANN’s role as a policy development body. 

* Operational stability and reliability of the IANA function is imperative to 
the business operations of registry operators.

* One of the four principles identified in the NTIA announcement is: Meet the 
needs and expectation of the global customers and partners of the IANA 
services; and this should be a primary consideration of the development of
a transition proposal. 

* As direct customers of the IANA service, registry operators (ccTLDs and gTLD) 
should have prominent representation on any oversight committee or organisation 
intended to replace NTIA’s role. 

* Registry operators should have the casting vote on any future decision to 
remove the IANA function from ICANN; however, any decision to remove the IANA 
function from ICANN must be for reasons of continued poor performance or 
incompetence. 

* The current performance of the IANA service as it relates to naming functions 
is satisfactory. There have been many improvements in the quality of service in 
recent years and this can be attributed to the IANA Department responding to 
the needs of their customers as well as adhering to the requirements and SLAs 
contained in the contract between NTIA and ICANN as the IANA Functions 
Operator.  

* There must be no transition of the NTIA oversight of the IANAfunctions before 
the conclusion of the Accountability CWG discussions and as such no transition 
proposal can be submitted to the ICG until the implications of any 
recommendations from the Accountability CWG, as it pertains to the IANA 
function, are understood.

Regards

Donna

Donna Austin
Policy and Industry Affairs Manager
ARI Registry Services