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Summary and analysis of public comments on EAG reporting

  • To: "eag-feedback@xxxxxxxxx" <eag-feedback@xxxxxxxxx>
  • Subject: Summary and analysis of public comments on EAG reporting
  • From: Kevin Wilson <kevin.wilson@xxxxxxxxx>
  • Date: Mon, 24 Aug 2009 09:26:32 -0700

Summary and analysis of public comments for:


Comment period ended: 13 July 2009

Summary published:  24 August 2009

Prepared by:  Kevin Wilson, CFO


As one important element of transparency and accountability, ICANN strives to 
publish meaningful, accessible financial and operational information. Through 
its history, ICANN has consistently increased the quantity and quality in the 
amount of detail provided in its financial reporting. Within the last 24 
months, for example, ICANN developed monthly dashboard reporting on financial 

In response to community requests to view ICANN's expenses in reports more 
aligned with stakeholder interest areas, ICANN has developed a new financial 
report: Expense Area Group (EAG) reporting (formally known as Cost Analysis 
Group). The categories depicted in this view of ICANN's budget are based on 
ICANN's organizational structure.

The attached 
paper<http://www.icann.org/en/financials/eag-analysis-29may09-en.pdf> [PDF, 
272K] describes the Expense Area Group reporting, the analysis and methodology 
used to create these reports, and more information on cost accounting at ICANN.

This new EAG reporting is simply one more view of ICANN's finances, equal in 
importance with a functional representation, or a representation by ICANN's 
accounting codes. In fact, no single representation captures the fundamentally 
interconnected nature of ICANN's work and mission. ICANN is responsible for 
coordinating the Internet's unique identifiers at a global level, which is only 
possible when all of ICANN's organizational structures are working with each 
other, and on a global basis. Still, this EAG analysis provides another useful 
way to understand the totality of ICANN's financial operation.

This comment period was intended to encourage community members to provide 
feedback on this new financial report, to help ensure that this type of 
reporting is responsive to the needs of the community.

As of the 13 July 2009 deadline, a total of 6 community submissions have been 
made by groups and individuals to this comment forum; after the deadline, an 
additional 4 community submissions have been received from groups and 
individuals. The comments were submitted by five separate groups and five 
individuals (including two advertisements). The contributors are listed below 
in alphabetical order (with relevant initials noted in parentheses):

At-Large Advisory Committee (ALAC) (submitted on 14 July 2009 after the close 
David Archbold (DA)
GNSO Registries Constituency (RyC)
GoDaddy.com (GD) (submitted on 14 July 2009 after the close date)
Henoxx (HEN)
Lesley Cowley (LC)
Mathieu Weill (AFNIC)
Michael D. Palage (MP)
Rami Shaker (RS) (advertisement submitted on 14 July 2009 after the close date)
Support Web Software E.U. (SW) (advertisement submitted on 12 August 2009 after 
the close date)


Comments submitted to this public forum tended to address or be directed toward 
three main thematic areas

1.       Appreciation for the enhanced reporting;

2.       Concerns with the EAG methodology used; and

3.       Areas where further enhancements can be made to EAG reporting.

1.       The comments made on the first theme related appreciation for the 
enhanced reporting included:

·         GD stated that they would like to thank ICANN for providing this 
analysis of projected expenditures in the FY10 budget, according to Expense 
Area Group (EAG). GD also mentioned that they are pleased that previously 
communicated concerns were given thoughtful consideration.

·         ALAC stated that they commend the ICANN Board and financial 
management team on the greater transparency in its financial operations visible 
in the current FY budget and they look forward to further efforts of this kind 
to make ICANN's financial operations more transparent.

·         RyC complimented the ICANN Staff for the EAG reporting document and 
the Board Finance Committee for their encouragement of that effort. RyC stated 
that the EAG reporting accomplishes the following critical objectives: It 
clearly shows reasonable estimates of ICANN expenditures provided to support 
each of ICANN’s supporting organizations and advisory committees as well as 
other key expense area groups; It provides an objective financial measure of 
the services that ICANN provides in support of each key expense area group; It 
gives the data necessary to compare ICANN’s sources of revenue from each group 
to the expenditures allocated for support of that group.

·         RyC also stated that they “believe that for the first time key 
expense area groups can specifically quantify the services they are provided by 
ICANN in monetary terms.  Judging by some of the preliminary feedback heard, it 
appears that some groups had little or no idea of all of the services provided 
to support their areas of interest, let alone the cost to do so.  This is a 
fundamental prerequisite to full participation in the budget process by all 
ICANN interest groups.”

·         MP stated that the ICANN CFO and the ICANN Board finance committee 
should be complimented for release of this document, as it represents an 
important step toward increased transparency and accountability in connection 
with ICANN finances.

·          AFNIC stated that they welcome the publication of ICANN's expense 
analysis as the publication itself is a significant step in increasing 

2.       The comments made on the second theme related to concerns with the EAG 
methodology used or other questions arising from the analysis of some EAG and 
associated expense allocations included:

·         DA stated that the Fully Allocated Costing methodology described in 
this paper is fairly traditional, using as it does Direct, Indirect and Fixed & 
Common (called “Administrative” in the paper) costs.  DA mentioned that 
although this can be useful as a management and budgeting tool, you can run 
into serious problems if its use is extended to form the basis of cost 
recovery. For example, with regard to the allocation of the cost of “IANA 
functions services”, we need to know the total cost involved and how it is 
calculated, as well as the ratios that are used to distribute these costs. DA 
added that it is essential that the assumptions and formula are published and 
agreed by the parties involved.

·         GD raised a concern regarding the disparity between gTLD and ccTLD 
revenues and related expenses. For example, GD stated contributions from gTLD 
organizations are subsidizing many of the expenditure outlays for activities 
that exclusively benefit the ccTLD space. ICANN should continue to work with 
ccTLD registries, sponsors, and their representatives on the GAC, to bring 
ccTLD expenses in line with expected contributions.

·         MP recommended the use of time sheets among ICANN staff to provide a 
much more detailed record to document for the Internet and ICANN community on 
how their money was being invested. MP added that the use of time sheets should 
also be used by ICANN's consultants and lobbyists.

·         AFNIC stated that it is essential that ICANN engages with all parts 
of the community to ensure that the figures and accounting principles are 
appropriately understood.  AFNIC believes improvements are needed to achieve 
this goal, especially related to costs that are often shared among several 
EAGs. To increase transparency and accountability in those estimates AFNIC 
stated that it is necessary to provide data on how those shares are calculated.

3.       The comments made on the third theme related to areas where further 
enhancements can be made to EAG reporting included:

·         GD stated that they appreciate that ICANN has been forthcoming in 
disclosing compensation information for key staff members, but requested to see 
additional transparency in this area, particularly in regard to incentive plans 
for employees and executives and how the progress of ongoing initiatives (e.g., 
new gTLDs and IDN adoption) affects staff compensation.

·         GD also stated that given the significant expense involved with 
travel (staff and supported volunteers) and meeting logistics, they want ICANN 
to continue its examination of travel support policy and the planning of 
meetings and events.

·         GD also stated that ICANN should provide additional details on its 
expenses related to government relations. Specifically, which individuals or 
agencies are being contacted and on which issues ICANN is offering 
consultations or opinions.

·         ALAC recommended more direct links in reporting between budget 
allocations and actual expenditure, and the link between financing for 
initiatives and their outcomes.

·         RyC recommends ICANN provide a table that compares revenue 
contribution amounts with percents and expense amounts with percents side by 
side for each EAG.

·         LC stated that in order to inform community dialogue going forward, 
Nominet would also like to see: an analysis of ccNSO costs by functional area; 
a separation and presentation of core ccNSO costs, so that Nominet can review 
base line ongoing costs; and a separation and presentation of significant 
project costs.

IV. Next Steps

ICANN Staff has synthesized these comments, and will continue to provide more 
analyses and reporting both as part of the annual budgeting process and 
periodic reporting on financial results.   In particular, ICANN staff will meet 
with the ccNSO working group to present the analyses of the “cc” section to 
show the functional parts of that section.   Along with the functional 
reporting, the “EAG” reporting format will be evaluated to ascertain whether 
it’s format is an effective tool for reporting.

Thank you
Kevin Wilson

Attachment: Summary and Analysis of Public Comments EAG 8-21-09.pdf
Description: Summary and Analysis of Public Comments EAG 8-21-09.pdf

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