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Summary and Analysis of Public Comments on Interim Report of Geographic Regions Review Working Group

  • To: "geo-regions-interim-report@xxxxxxxxx" <geo-regions-interim-report@xxxxxxxxx>
  • Subject: Summary and Analysis of Public Comments on Interim Report of Geographic Regions Review Working Group
  • From: Robert Hoggarth <robert.hoggarth@xxxxxxxxx>
  • Date: Thu, 10 Feb 2011 19:56:54 -0800

Summary and Analysis of Public Comments on Interim Report of Geographic Regions 
Review Working Group

Comment period ended: 30 January 2011
Summary published: 10 February 2011

Prepared by: Robert Hoggarth, Senior Policy Director


I.  BACKGROUND

Geographic diversity is a fundamental component of the ICANN organization. The 
ICANN Bylaws (Article VI Section 5) currently define five geographic regions as 
Africa, North America, Latin America/Caribbean, Asia/Australia/Pacific and 
Europe.

The ICANN Geographic Regions were originally created to ensure regional 
diversity in the composition of the ICANN Board and were subsequently expanded 
in various ways to apply to the Generic Names Supporting Organization (GNSO), 
At-Large Advisory Committee (ALAC) and the Country Code Names Supporting 
Organization (ccNSO).

Over time, community members have developed concerns about the implementation 
of the ICANN Geographic Regions and related representational issues. The ccNSO 
Council approved a resolution in 2007 recommending that the ICANN Board appoint 
a community-wide working group to further study and review the issues related 
to the definition of the ICANN Geographic Regions, to consult with all 
stakeholders and submit proposals to the Board to resolve the issues relating 
to the current definition of the ICANN Geographic Regions.

The rest of the community supported the concept of the working group and the 
Board authorized its formation at its December 2008 Meeting (see - 
http://www.icann.org/en/minutes/resolutions-07nov08.htm - 
_Toc87682556<http://www.icann.org/en/minutes/resolutions-07nov08.htm#_Toc87682556>).

The Board approved the charter of the Geographic Regions Review Working Group 
(hereinafter “the Working Group” or “the WG”) at its public meeting in June 
2009 (see - http://www.icann.org/en/minutes/resolutions-26jun09.htm - 
1.2<http://www.icann.org/en/minutes/resolutions-26jun09.htm#1.2>).

The Charter authorized by the Board outlines a three-part process beginning 
with an Initial Report(see 
http://www.icann.org/en/public-comment/public-comment-200909.html#geo-regions-review,
 followed by an Interim Report and finishing with a Final Report.  The Working 
Group completed part two of its work with the Interim Report that is the 
subject of this proceeding.

II.  GENERAL COMMENTS and CONTRIBUTORS

As of the 30 January 2011 closing date of this proceeding and through the first 
week of February, four (4) substantive and relevant community submissions had 
been made to this comment forum. The Working Group also collected comments from 
the community at a Workshop held on 9 December 2010 during the ICANN Public 
Meeting in Cartagena, Columbia (see http://cartagena39.icann.org/node/15465 - a 
transcript of the comments from that Workshop are included in this summary 
document).

The parties commenting in writing included:

Antony Van Couvering, CEO, Minds & Machines
Maureen Hilyard, Vice Chair, Pacific Chapter of the Internet Society
The Country Code Names Supporting Organization of ICANN (ccNSO)
The At-Large Advisory Committee of ICANN (ALAC)
The ALAC submission included an appendix section containing contributions from 
the five At-Large Regional At-Large Organizations (RALOs):
AFRALO;
APRALO;
EURALO;
LACRALO; and
NARALO
Among the various RALOstatements appended to the ALAC statement were also a few 
individual comments from RALO members that are quoted in this summary including:
Will Tiben, APRALO;
Siranush Vardanya, APRALO; and
Edmon Chung, APRALO

Community members who participated in the Working Group’s Cartagena Workshop 
who are quoted in this summary from the workshop transcript include:

Fouwad Bajwa, APRALO
Tijani Ben Jemaa, AFRALO
Eric Brunner-Williams,NARALO
Keith Davidson, Dot .nz and Chair of Asia/Pacific Top Level Domain Association 
Khaled Fouda, League of Arab States
John Lawrence, AusRegistry International
Mike Roberts, ICANN Nominating Committee Member


III.  SUMMARY & ANALYSIS

General Disclaimer:  This document is intended to broadly and comprehensively 
summarize the comments submitted to this Forum, but not to address every 
specific position stated by contributors.  Staff recommends that readers 
interested in specific aspects of any of the summarized comments, or the full 
context of others, refer directly to the specific contributions at: 
http://forum.icann.org/lists/geo-regions-interim-report/

Although limited in number, the comments received raised a number of issues 
that the Working Group will need to consider as it considers what, if any, 
recommendations to make to the ICANN Board.

Several commenters encouraged the Working Group to take an active role in 
making recommendations to adjust the ICANN Geographic Region framework.

Commenters addressed a variety of topics.  Some topic areas unavoidably and 
necessarily overlap.  One category of comments addressed the scope of the 
Working Group’s potential recommendations.  A number of comments said the WG 
should not feel constrained to recommend adjustments to the geographic regions 
framework.  A second category of comments focused on the types of adjustments 
the WG should recommend. The full list of issues and matters raised by the 
commenters include:

A.  The Scope of Potential Recommendations Available to the Working Group;
B.  A Caution About Unintended Consequences;
C.  Opinions Regarding the Existing Geographic Regions Framework;
D.  How To Classify Regions – Options for Working Group Recommendations;
E.  Option - Considering the Creation of New Regions - A New Region for “Small 
Island Developing States”;
F.  Option - Relocating Specific States to More Appropriate Regions;
G.  Considering the Purpose of Geographic Diversity in ICANN Processes;

H.  Culture, Language and Other Measures of Diversity; and
I.   The Need to Regularly Review The Geographic Regions Framework

Comments regarding each of these issues and matters are quoted or summarized in 
a specific section below.  Due to the overlap of some issues you may note that 
a few select quotes are repeated.

A.  Scope of Potential Recommendations Available to the Working Group:

The ccNSO believes that “in developing its conclusions and Final Report, the 
Working Group should not feel beholden to the legacy intentions or purposes 
that drove ICANN to adopt geographic regions. The Council believes the Working 
Group’s conclusions should not focus on whether the adoption of five regions 
was “reasonable and defensible” in 2000, but rather upon the current needs of 
ICANN, its SO’s and AC’s and all stakeholders.”

Mr. Van Couvering agrees.  He says, “I encourage the Working Group to adopt 
definitions and policies that work for ICANN today, not what worked for the 
NTIA eleven years ago.”

Keith Davidson the Chair of the Asia/Pacific Top Level Domain Association which 
currently has 36 of the 72 Asia/Pacific located countries as members, commented 
at the December 2010 Working Group Workshop in Cartagena, Colombia, “I don’t 
think you can find another model which will fit, so this is a bottom-out 
process of finding what suits within ICANN solely.  So my suggestion in that 
instance is that you start again with ignoring any existing structure, 
including the existing ICANN structure.”

Reiterating a position it asserted back in 2007, the ccNSO says, “ICANN’s 
arrangements for the allocation of countries and distinct economies to regions 
must recognise the sovereignty and right to self-determination of states. The 
ccNSO says, “ICANN cannot issue prescriptive guidelines or become involved in 
interrelationships between countries and their outlying territories. ICANN 
should retain a degree of flexibility and recognize both the established 
preferences of sovereign states and the preferences of their territories, if 
supported by the sovereign.”

The ccNSO also cautions, “ICANN’s arrangements for the allocation of countries 
and distinct economies to regions must recognise the sovereignty and right to 
self-determination of states.”

B.  A Caution About Unintended Consequences:

Commenters make a number of specific suggestions about particular adjustments 
that could be made to the Geo Regions framework (see below), but commenters 
also recognize the challenges of making any changes at all.

For example, Keith Davidson said at the Cartagena Workshop that, “one of the 
issues about dividing the massive Asia/Pacific region is that when you start to 
look at methodologies of division, you can get into culture and language issues 
where you could upset other apple carts.  For example, the Middle East scene is 
quite a distinct region, but the North African states that share the language 
probably feel that they would belongmore together with that smaller sub-region, 
so you may be creating more problems than it’s worth.”

C.  Opinions Regarding the Existing Geographic Regions Framework:

ALAC says it is “satisfied” with the current ICANN regions structure, but that 
it is concerned that “proposals to introduce new ICANN regions or splitting the 
current regions [could] severely affect and fragment the current At-Large 
structure.”

AFRALO says it has “no objection” to the current ICANN geographic region 
structure and distribution.  The organization asserts that, “the current ICANN 
regions [framework] fit its purposes.”

The EURALO said it supports maintaining the existing regional model at ICANN. 
“As a general rule,” Euralo says, “we would like to suggest some considerations 
on exceptional or border cases and to introduce a new “principle of 
self-determination” for such particular border cases. We are conscious that 
exceptions always need to be well justified to avoid abuses. And such a 
“principle of self-determination” needs to be further discussed and specified 
on particular circumstances, procedures of consultations, mutual approval and 
decision- making.

D. How To Classify Regions – Options for Working Group Recommendations:

1.  Physical Location:


Mr. Van Couvering says, “I urge the Working Group to recommend using 
definitions that recognize the actual physical location of a country of 
territory rather than its political affiliations.  This would be most helpful 
for regions where colonialism still flourishes, notably in Oceania and the 
Caribbean. He says, “ICANN is under no obligation to contort itself to 
recognize vestiges of occupation.  Nations and territories in the Caribbean 
(for instance) are actually in the Caribbean, not in Europe, and their cultures 
and their people for the most part identify themselves as Caribbean.

2.  Considering the Option of Sub Regions:

Contributing to the APRALO section of the ALAC comment package Fouad Bajwa 
introduces the possibility of sub regions being formed within APRALO.  He 
specifically denotes Small Island Developing State (SIDS) sub-regions and an 
Arab sub-region. In his APRALO contribution, Edmon Chung also supports this 
idea.

Khaled Fouda also seemed to agree with this idea at the Cartagena Workshop – 
particularly with respect to the creation of an Arab Region.  Noting that ICANN 
had identified an Arab region for the purposes of new gTLDs he said, “the Arab 
region is sort of a defined region with 22 member states that share the same 
language, the same culture, the same models and many things, actually.  So is 
there also a way where we can work on defining the Arab region as part of the 
ICANN region in general, and not only just for new gTLDs?”

John Lawrence, from AusRegistry International also likes this concept.  At the 
Cartagena workshop he said, “I think we would certainly encourage regions like 
the Arab States to start developing their own sort of informal conferences on 
an annual basis.  And I think that potentially provides kind of a bottom-up 
approach, and if these things are viable and start to make sense, then perhaps 
in time they can be looked at as potential sort of proto-regions or whatever 
they might become.”
E.  Option - Considering the Creation of New Regions - A New Region for “Small 
Island Developing States”:

Maureen Hilyard is the Vice Chair of the Pacific Chapter of the Internet 
Society.  In her written comments she observes that, “the ICANN list of 
countries excludes some small island developing states from participating in 
ICANN and other similar meetings as members in their own right.”  Ms. Hilyard 
asserts that, “small island states are usually ‘lumped’ together with larger 
countries and continents because of their proximity but with little 
consideration for their greatest barrier to development - their isolated 
situations within large expanses of ocean.”  As such, she recommends, “ICANN 
consider the creation of another region (or another special interest group) 
that represents the needs and concerns of small island states within the 
Pacific (and perhaps similar small island states currently assigned to other 
regions.)”

Ms. Hilyard observes that, “the uniqueness of each of Pacific Islands as a 
geographic category is demonstrated by the following factors:


 *   The range in population - from 50 (Pitcairn Island) to seven million 
(Papua New Guinea)
 *   The range from completely independent republics to countries that remain 
territories of large countries (e.g., United States, France and the United 
Kingdom)
 *   Their internal administration by single government entities, to multiple 
provincial governments
 *   The range in size and composition from one small island of 21 sq kms 
(Nauru) to a portion of a large land mass plus 30 groups of islands (Papua New 
Guinea).”

ALAC says, “We understand and acknowledge legitimate requests and issues raised 
related to the current ICANN regions. And ALAC specifically notes “the islands 
nations geographical split between more than one region based on geography and 
administrative/legal reasons.”

LACRALO also suggests, “there is merit in having a new grouping specific to the 
needs of Small Island Developing States like ours. Many of the smaller islands 
in our region are not represented because of limited resources and we agree 
that ICANN’s structures and processes should lower barriers forparticipation 
and engagement by community members as much as practicable. By forming this new 
grouping we can leverage on our collective skills to support smaller members 
not only in the Caribbean but globally, who will have almost identical issues.” 
 LACRALO cautions, however, that “perhaps the main drawback with a SIDS RALO 
would be that we would be geographically dispersed and have to travel long 
distances for face to face meetings such as a General Assembly.”

In hisstatement accompanying the ALAC comments, Will Tiben of the APRALO also 
acknowledges and supports Ms. Hilyard’s comments regarding small island nations.

F.  Option - Relocating Specific States to More Appropriate Regions:

Council of Europe Member Relocation:

Both the EURALO and Siranush Vardanya of the APRALO recognized the circumstance 
that CoE Member countries like Armenia, Azerbaijan or Georgia are considered in 
the ICANN framework as part of the Asian region.

ALAC says, “We understand and acknowledge legitimate requests and issues raised 
related to the current ICANN regions. ALAC specifically mentions “the status of 
some Eastern countries like Armenia and Azerbaijan whom according to ICANN 
regions are part of Asia Pacific region while in other international fora 
theyare members of the European region.”

Caribbean Realignment:

The LACRALO comments submitted with the ALAC comments suggest that the Working 
Group consider recommending the Caribbean be re-aligned with the NARALO.  
LACRALO says, “The Caribbean is distinct in terms of its history, culture and 
language; further it has indigenous challenges being small island states and 
specific needs which are not a natural fit with the rest of Latin America.” 
LACRALO says “both NARALO and the Caribbean Region share the same language and 
akin perspectives on many areas, including our view of democracy.”

G.  Considering the Purpose of Geographic Diversity in ICANN Processes.

In itscomments the ccNSO said it ‘supports the development of structures and 
policies relating to ICANN’s use of geographic regions that are consistent, 
reviewed regularly, and facilitate balanced participation and representation 
from all countries, irrespective of location or economic status.”

Similarly, the LACRALO says it is “supportive of the GNSO Principle on 
Potential Change of Regions (August 2008) which states that ‘ICANN regions 
should seek to balance three goals: diversity of representation, ease of 
participation, and simplicity’ and such simplicity ‘should be balanced with the 
evolving needs of ICANN’s supporting organisations and other bodies.’

Other commenters focused on specific aspects of participation and 
representation.

1.  Participation:

The NARALO supports “investigating ways to increase the participation of 
Indigenous populations, especially those whose cultural territory cuts across 
regional boundaries.” The NARALO says it would “strongly oppose any regional 
model (such as the ITU) that would amalgamate all of the Western Hemisphereinto 
a single ‘Americas’ region.”

The EURALO says, “if we want to encourage a broader bottom-up participation and 
inclusion of more Internet users at ICANN, we need to create conditions for 
participation reflecting the cultural particularities and sensitivities of 
motivated people and potential ALSes.”

In recommending that some special consideration be given to small island states 
in the Pacific region (and other regions if they wish), Maureen Hilyard 
particularly notesthat such designations would enable representatives of those 
states to be assigned their own “regional area” or be given “special interest” 
status “so that during ICANN meetings they may be able to raise and discuss 
issues andconcerns that are applicable to the technological and internet 
development of small island states globally.”

2.  Representation:

ALAC says, “as the demography of internet users is changing and millions of new 
internet users are joining the internet from emerging or developing countries, 
the Geographic Regions Working Group Interim Report recommendations should 
encourage ICANN constituencies (AC/SOs) to review their current membership 
frameworks to address issues of under-representation of those regions and 
encourage more active participation from the least represented or active 
geographical regions.”

Keith Davidson notes that there is more than one way to look at the issues.  He 
says, “One [i]s the representation methodology within ICANN and the second is 
how to not even think about regions but think about issues and where you have 
commonality of issues.”

As a current ICANN Nominating Committee member, Mike Roberts cautions about 
treating the Geographic Regions framework as a cure-all for representation of 
culture and diversity.  At the WG Cartagena Workshop he said, “And so the 
notion that one person could represent the diversity of that big chunk of 
geography and culture and language and economies just doesn’t really compute.
And there are similar examples, I think, all around the globe, so I’m very 
pleased with the progress that you’ve made.”  He continued, “I guess the notion 
is we ought to try to turn down the volume on the notion that the regions have 
representational value that borders on entitlement because that leads us to a 
place where we really don’t want to be.”


H.  Culture, Language and Other Measures of Diversity:

ALAC notes that the concept of geographic diversity could also expand to 
include considerations of cultures and languages.  The ALAC comments say, ”With 
specific reference to the Interim Report question on how to ensure cultural 
diversity, the ALAC encourages the AC/SOs to seek membership of 
organizations/entities to represent more cultural and linguistic diversity.”


The LACRALO observes that, “the defined geographic region of LACRALO has in the 
past detracted from ICANN’s goal of reflecting the functional,geographic and 
cultural diversity of the Caribbean Region of Internet end-users.  The LACRALO 
“agree[s] in the broader recognition of ‘diversity’ to include additional 
considerations of culture and language in the LACRALO. The Caribbean is 
distinct in terms of its history, culture and language; further it has 
indigenous challenges being small island states and specific needs which are 
not a natural fit with the rest of Latin America. Due to these differences 
LACRALO is able to benefit from varying opinions and has the potential to be a 
truly representative region.” One small but important example, according to 
LACRALO, is the predominant use of the English language in the Caribbean 
Region, “however 90% of the mailing list discussion takes place in Spanish”, 
according to LACRALO.

At the Cartagena Workshop, Eric Brunner-Williams from the NARALO observed that 
there are additional choices for how ICANN “split[s] up the world.”  He said,  
“one was referred to by the head of the Asia/Pacific TLD Organization, which is 
the legal culture, that is similarity of legal cultures being an organizing 
principle.
The other one … is the Network Operator Group Locality of Interest.  So we have 
the North American Operators Group; we have RIPE; we have the Middle East 
Operators Group; we have the A/P Network Operators Group.  These are localities 
of service providers who provide the access network and the transit network for 
ultimate users of the DNS, our users.  So that’s another possible dividing 
principle is basically through the nexus of wire bundling.”



Tijani Ben Jemaa from ALAC would also seem to agree with this line of thinking. 
 At the Cartagena workshop he said, “I don’t think that that is a real 
interest, but we have to think about the regional division; we have to think 
about this creation of internet in those regions.  Geographic division, but 
with this creation of the internet, the internet users, the industry of TLDs, 
etc.  So if we can, if we try to do that, perhaps we will have another 
division, which is not very far from the division, the actual division, but 
which will be, perhaps, more useful for ICANN.”



ALAC says, “Value could be added to the ICANN policy development process and 
each AC/SO could employ tailored procedures to ensure diversity among its 
members.”

I.  The Need To Regularly Review The Geographic Regions Framework

ALAC says, “the Geographic Regions Working Group [should] recommend a regular 
review of ICANN regions framework every five years review, the review should 
focus in assessing ICANN regions impact on the issues representation and 
participation within ICANN AC/SOs.”

The ccNSO comments also reinforce the concept of regular review.


IV.  NEXT STEPS

The Working Group members will review and consider the substance of the 
submitted comments as they develop their Final Report recommendations, if any, 
for the ICANN Board. Once that Final Report is published, it will also be made 
available in all six UN languages for community review and comment before it is 
formally reviewed by the Board.

#  #  #


Attachment: Summary and Analysis of Interim Report of Geographic Regions Review Working Group (10Feb2011).doc
Description: Summary and Analysis of Interim Report of Geographic Regions Review Working Group (10Feb2011).doc



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