Depository, Inc. Response to ICANN Request for Consultation - INR

[peter.thimmesch@xxxxxxxxxxxxxx]

Mr. Vegoda,

Please find attached and embedded below Depository, Inc.'s response to  
ICANN's Request for Consultation on Internet Number Resources  
Performance Standards.  Thank you for the opportunity to share our  
thoughts and this important matter.  Please contact me at  
peter.thimmesch@xxxxxxxxxxxxxx if you have any questions regarding our  
submission.

DEPOSITORY, INC. RESPONSE TO ICANN
CONSULTATION ON INTERNET NUMBERS PERFORMANCE STANDARDS

December 11, 2012

OVERVIEW

Depository, Inc. (Depository) is pleased to submit a response to the  
Internet Corporation for Assigned Names and Numbers’ (ICANN) request  
for Consultation on Internet Number Resources Performance Standards.   
Depository is an independent Internet number registry providing an  
array of value-added Internet number registry services to our  
customers.  As such, Depository and our customers are “interested and  
affected parties,” as defined in Sections C.1.3 and C.2.8 of Contract  
SA1301-12-CN-0035 (the “Contract”) between ICANN and the Department of  
Commerce (DoC), National Telecommunications Information Administration  
(NTIA).  Depository is one of thousands of ICANN-community  
stakeholders, including tens of thousands of Legacy IPv4 number block  
owners, whose voices have been ignored until now by the current  
Internet Number Resources (INR) scheme.  Depository applauds ICANN for  
following through with its contractual obligation under C.2.8 of the  
Contract and hopes ICANN will seriously consider ideas of all  
“interested and affected parties” to improve and expand the INR system  
for all stakeholders.
ICANN’s request for consultation deals with Performance Standards for  
allocation services only within the INR system.  Allocation is an  
important activity to be sure, but it is not the only function  
performed in the INR system and is not the only function that should  
be included in the Key Performance Indicators (KPIs).  Other functions  
currently performed by five Regional Internet Registries (RIRs) under  
minimal or no oversight by ICANN are:
•       Directory Services (WHOIS).
•       DNS delegations (and aggregation) for in-addr.arpa.
•       in-addr.arpa DNS resolution for parts of in-addr.arpa.
•       Routing policy publication.
•       Routing security services (RPKI).

To further punctuate the need for KPIs for post-allocation services,  
soon the allocation function will no longer be necessary for IPv4, but  
at the rate of IPv6 adoption, IPv4 will continue to need  
post-allocation services for many years to come.  It is with this fact  
in mind that Depository addresses Questions 2 and 4 of the request for  
consultation.  Depository respectfully puts forth suggested immediate  
actions and Performance Standards or reporting metrics in the areas of  
contracts, competition, documentation, accuracy, transparency, and  
process quality.
Contracts

The key to ensuring compliance with any Performance Standard or metric  
devised lies in contract.  Allocation and post-allocation services are  
conducted currently only by five independent RIRs who are not under  
contract with ICANN or any other authoritative party, including the  
DoC/NTIA, to do what they do.  They are all private companies with  
their own interests that may or may not align with the interests of  
the entire stakeholder community.  Therefore, no meaningful  
Performance Standards can be made to apply to them under the current  
paradigm even if they are agreed to by the “community” and implemented  
herewith by ICANN.  It is a false assumption and misunderstanding of  
the current INR structure to believe otherwise.  To address this,  
Depository recommends the following with respect to contracts:
•	ICANN shall promptly develop a Registry/Registrar model for the INR  
similar to the model employed for DNS.  Registrars shall be allowed to  
provide services without connectivity as a requirement.
•	ICANN shall collect from the Registry/Registrars and report all  
metrics similar to those already established for the DNS model,  
including, but not limited to aggregate details on Internet numbers  
under contracts with Registrars versus numbers not under contract with  
Registrars (i.e., Legacy IPv4 number block owners).
•	ICANN shall report metrics on any contracts for the update and  
maintenance of resolution related to Internet numbers (in-addr.arpa,  
etc.).
•	ICANN shall report metrics on any IANA Functions services delegated  
to third parties, but not under formal contract with ICANN, such as  
ICANN’s responsibility to update the IANA Registries.
•	ICANN’s goal shall be to have reporting on 100% of the contracted  
and non-contracted IANA Functions.
Competition

ICANN shall establish, maintain, and report metrics on progress  
towards competition amongst Registrars for allocation and  
post-allocation services consistent with ICANNs charter to foster  
competition in Internet numbers.  The metrics shall include, but not  
be limited to:
•       Number of Registrar applicants from each region.
•       Number of active Registrars in each region.
•       Transfers of number blocks between Registrars.
•       Transfers of number blocks between Legacy IPv4 number block owners.
•       Name of all Registrars.
•	Other competition metrics similar to those currently captured in the  
DNS Registrar model.
 
Metrics goals shall be to:

•	Track and monitor satisfaction of all “interested and affected  
parties” with the Registrars and the services they offer.
•	Provide the Internet community, which ICANN serves, with information  
and resources to assist in choosing a Registrar providing services  
that meets their business needs.
Documentation

ICANN shall ensure all INR community processes, procedures, and  
policies are clearly documented in a consistent manner.  This level of  
documentation coverage should be tracked as a KPI of ICANN.  The clear  
documentation shall be developed and implemented for:
•       Conflicts of interest, where present, and special interests.
•       Updating of the IANA WHOIS.
•       Updating of the InterNic WHOIS.
•       Data Escrow and Data Escrow Agreements.
•       Bulk Access.
•       Zone File Access.
•       Reserved Numbers.
•       Registrar service levels.
•       Number block restrictions.
•       Dispute resolution.

Accuracy

Directory Service (WHOIS) accuracy should be tracked as a KPI,  
including both IANA WHOIS and other WHOIS.  Allocation data, including  
accounting of IP number gaps, should be accurate.  The Registry should  
report performance indicators on the amount of space being used that  
is not authorized.  All relevant TLDs should have a Registry provider.  
 Accuracy should be defined as any contact information or company’s  
name that is not factually correct.  In the case of the current IANA  
WHOIS of 256 records, over 70% indicate incorrect information.
Transparency

Content on the ICANN website should be consistent with established  
processes, procedures, and policies.  All contracts should be  
publically available for the operations and maintenance of .arpa,  
including ip6.arpa and in-addr.arp.  Information about any IANA  
Functions not under formal contract with ICANN should also be publicly  
disclosed.  This disclosure should explain the reason for the lack of  
a formal contract to carry out the function.
Timeliness & Process Quality

ICANN shall report on the service levels and quality for all processes  
and procedures, including, but not limited to:
•       Response times on IP number allocation requests.
•	Numbers of approvals and numbers of denials for IP number requests.   
If denials, reasons for the denials.
•	Number of registry update requests; time to update record upon  
receipt of update request.
•       Details on performance of updates to routing policy, reverse lookups, 
etc.
•       Queries per second for in-addr.arpa.
•       Average response time for DNS resolution.
•       Percentage up time and down time for provided services.

Conclusion

The crisis looming for the INR community has eclipsed the crisis that  
once faced the DNS world.  While the biggest Internet asset many  
Internet community members have is their IPv4 number block(s), they do  
not currently have the infrastructure and support they need to ensure  
security in their asset(s) and the iron-clad ability to use them  
without interruption to grow their business.  The metrics, such as  
they are, and the Performance Standards in place today are woefully  
inadequate to continue to provide a robust and vibrant INR system.   
While IPv6 may be a long term solution, the prohibitive cost of dual  
stacking for many businesses will leave them looking for other  
alternatives in the IPv4 protocol for many, many years to come.  It is  
ICANN’s charter and ICANN’s obligation under its Contract with the DoC  
to establish a framework for the management of IPv4 numbers that works  
for all “interested and affected parties.”  Performance Standards is  
just one part of that framework.

Attachment: DEPOSITORY RESPONSE TO ICANN KPI CONSULT - 12-11-12.pdf
Description: Adobe PDF document