Comment on ICANN's CCWG Accountability draft proposal

[Narine Khachatryan <ms.narine.khachatryan@xxxxxxxxx>]

Dear Sir/Madam,

​Media Education Center (Armenia) appreciates the opportunity to submit
comments
on the CCWG-Accountability Draft Work Stream 1 Recommendations. We
would like to thank the CCWG on Accountability for its hard work in
compiling this report. This is a crucial step in the transition of the
oversight over ICANN from the US government to the global community,
which is generally welcomed.

​Media Education Center
 especially welcomes the inclusion of the bylaw
language reaffirming and clarifying ICANN’s obligation to respect
human rights.

We find the proposal for bylaw language on human rights to be clear
and balanced. We appreciate the fact that it limits the commitment to
ICANN's mission and operations only and provides a clear distinction
between ICANN's adherence to respect human rights and obligation to
enforce human rights, placing the latter outside of the scope of the
ICANN's mission.

We are aware of the discussions on the inclusion of particular human
rights related international legal instruments, such as Universal
Declaration of Human Rights (UDHR), the International Covenant on
Civil and Political Rights (ICCPR), International Covenant on
Economic, Social and Cultural Rights (ICESCR), into the bylaw
language. We welcome the proposed version of the bylaw language, which
does not refer to particular international legal instruments. In our
view, there is no need to outline specific international documents in
the bylaws since there is no reason in principle why particular
instruments (e.g. the UDHR) should be referenced at the expense of
other important international treaties.

At the same time, we agree that the issues related to the
applicability of international instruments in the context of ICANN's
commitment to
​ ​
respect human rights must be addressed in Work Stream 2.
We strongly
​ ​
support the proposal to include the interim bylaw for the purpose of
ensuring that Work Stream 2, which will facilitate the development of
the framework for interpretation of the human rights commitment, will
take place.

We further agree with the issues identified in Annex 6 of the Draft
which will be the subject of further work in Workstream 2.

We hope that Workstream 2 will be carried out in the same
collaborative, inclusive and open manner as the whole work of CCWG up
to now and will result in a clear framework for interpretation and
implementation of ICANN's commitment to human rights.​

​Narine Khachatryan,

On behalf of Media Education Center, At-Large Structure
Yerevan, Armenia​