CENTR response on ICANN Strategic PLan
Brussels, 24th February 2005
Paul Twomey President and CEO ICANN Suite 330, 4676 Admiralty Way Marina del Rey CA 90292 USA
Comments on the Draft ICANN Strategic Plan
The Council of European National Top Level Domain Registries, CENTR, wishes to take the opportunity to comment on the ICANN Strategic Plan 2003-4 to 2006-7.
CENTR acknowledges ICANN senior staff's efforts in drafting this document and in developing the strategic priorities that will guide ICANN's work in the forthcoming years. We welcome this opportunity for the community to give input on this draft, which we believe challenges our vision of a small ICANN devoted to co-ordination functions and based upon community consensus. We support the concept of an ICANN with a well-defined agreed scope and we appreciate the changes ICANN has undertaken to date to improve the dialogue with stakeholders and to build bottom-up consensus-based procedures. Our feedback on the plan aims to be a constructive step further toward working together for the benefit of the Internet community.
We respectfully submit these thoughts on areas of the plan which we believe require further attention.
General consideration and priorities ------------------------------------
Several parts of the plan focus on ICANN's achievements with long descriptions of past activities, internal procedures and staff organisation. While we recognise the need to explain the business to others in order to inform, motivate and evolve; we note that the sections dedicated to the strategies looking forward are significantly less detailed. It would be useful for ICANN to project itself in the future with a clear list of priorities, deliverables and milestones, ideally with specific target dates, then seek endorsement from the community.
We suggest the plan focus on short, medium and long-term goals, presenting concrete approaches to achieving bottom-up development and transparency, rather than alluding to them in non-specific terms.
The draft plan highlights a broad range of activities, but it would be interesting and useful for the plan to:
? focus on concrete goals and better identify the objective under the chapter entitled "continue a strong and appropriate role in supporting the security of the Internet"(page 24-25). As for the point of "establishing ICANN as a significant and active facilitator of network security research that directly enhances the stability of the DNS", we suggest ICANN avoids the risk of failure and leaves this important topic to the significant number of research organisations with a proven track-record in this area instead of running the risk of producing little (or no) results after high financial investments;
? provide an appendix listing the 60 initiatives that ICANN states it is currently running, ideally with the priority ranking they are given;
? specify the consultation methods to be used to identify "objectives requested from ICANN stakeholders" and the process for ensuring ICANN stays within its core area of competence.
CENTR members firmly believe that a well-functioning IANA is of crucial importance to ccTLDs. Therefore, they wish to highlight the significance of the IANA functions and introduce a clear path to make it run "professionally and efficiently", possibly by constantly informing the Internet community on IANA problems and developments.
While welcoming the proposal to strengthen the IANA services, we recommend any further progress to be developed in the earlier years of the plan. CENTR offers to facilitate a constructive dialogue between IANA and the ccTLDs to assist with guiding and implementing these improvements.
Operational and financial aspects ---------------------------------
While the plan lacks details in some parts, others are too operational or tactical. We suggest those parts to be moved to appendices dedicated to detailing them.
We note that ICANN proposes to increase its budget in the forthcoming years in order to cope with a series of initiatives it would like to undertake, including "high-speed transaction systems that automate operational processes where appropriate" and "a competent project management system will also facilitate the planning, management and reporting on the over 60 initiatives for which ICANN currently has responsibility".
The financial aspects are those of most serious concern, and indeed may impact the long-term future of the ICANN organisation. ICANN was originally intended to have a budget of circa $8 million a year, yet the plan indicates ICANN's expenditure budget will rise sharply to $22 million dollars in 2006-07. This is partly justified by the increase of the staff members. While some comparisons with registries are not completely correct, it would have been desirable to see ICANN's strategic plan attributing specific cost implications for each area of intended work in case the financial strategy fails to achieve its targets, as this may help focus ICANN's activities.
As a matter of fact, ICANN bases the future budget on rough estimates of incomes (such as "Contributions from other organisations" in the final paragraph), yet fails to identify these organisations. The margin for error is ignored as well as the potential risk of not being able to find alternative or new sources of revenue. The assumptions which the future revenue structure is based on are highly hazardous. Consequently, we strongly recommend the Strategic Plan considers multiple financial scenarios.
We note the ICANN now recognises that approximately $1m is a more realistic expectation of the contribution from the ccTLD community. That said, it remains useful for the community to review a detailed breakdown of the proposed budget to ensure ICANN operates efficiently and provision of the IANA service is not used to cross-subsidise other parts of the organisation.
As a matter of fact, bearing in mind that the plan projects a cost increase of 165%, CENTR urges a review of the funding methodology so that mechanisms for involving the ccTLDs that are not ccNSO members could be established and contributions from the ccTLDs community could be based on a more realistic cost-driven approach.
ccTLD and ICANN ---------------
With reference to relationships with ccTLDs, the plan reports that they participate in the ICANN process through the ccNSO. Unfortunately, the ccNSO is still in its infancy: to date less than 15% of the ccTLD community have joined the supporting organisation.
We congratulate ICANN efforts to make the ccNSO as inclusive as possible, and we appreciate that ICANN is taking into account some concerns of the ccTLD community has for the ccNSO bylaws. We are also conscious that some ccTLDs are negotiating some possible changes to the ccNSO bylaws before joining the process.
However, it is quite optimistic to believe that more than 50% of the ccTLDs will be represented adequately in the ccNSO by the end of the strategic plan. Therefore, we would like to see the plan including alternative ways of involving the ccTLDs in its policy development process.
Considering the new GAC principles, particularly in reference to subsidiarity, CENTR members believe that ccTLD policy needs to be set locally, unless it can be shown that the issue has global impact and needs to be resolved in an international framework.
External relations ------------------
The Plan identifies the need to implement a "building avenues of communication strategy". However, the way ICANN will develop it and the tools that will be used are not clear.
We are aware that ICANN staff has to deal with a considerable amount of requests on a daily basis from the world Internet community. However, considering the capabilities of modern technology and software, we strongly suggest the plan includes a detailed framework that utilises technology to deal with the "volume contacts" and to increase the internal communication among staff members, possibly introducing an effective 24 hour service that copes with the different time zones.
We recommend ICANN structures its communication strategy on the basis of two fundamental concepts: multilingualism and responsiveness.
Furthermore, taking into account that other actors have recently claimed a leading role in the Internet arena, and considering the goals the ITU has included in its work programme, it would be useful to illustrate the way ICANN intends to enlarge the dialogue with all the international organisations in the light of the WSIS process and in the context of the European Union. The Internet has been developed through peer-to-peer decentralised partnerships which are focused on core competencies. We believe that developing strong partnerships, founded on regular contact and reciprocal information exchange, with other organisations will help ICANN staff gain a broader vision of all the different issues that characterise the areas of ICANN's limited remit.
The CENTR community needs an efficient IANA and is happy for ICANN to provide that service and to manage its core technical functions efficiently and effectively.
ICANN can make a decisive step forward by updating this plan in light of comments received . Its objective is not only to demonstrate that its structure is capable of fulfilling its commitments, but it needs to show the ability to be farsighted, to effectively include all the Internet stakeholders, and to efficiently cope with the Internet infrastructure issues that may arise in the future.
CENTR members hope that this feedback will be of use to you in further developing the plan. We stand ready to provide you with further help to stimulate change and develop a sound foundation for the future, as well as to assist in appraising ICANN's performance.
We thank you once again for the opportunity to submit these comments.
Paul M. Kane Chairman CENTR
Giovanni Seppia General Manager CENTR Avenue Louise, 327 1050 Brussels Tel. +32-2-6275551 Fax +32-2-6275559 Mobile: +32-(0)473-820714