Nominet Comments on Draft Strategic Plan

[lesley.cowley@xxxxxxxxxxxxxx]

On behalf of Nominet, the country code Top Level Domain registry for .uk, 
I would like to thank ICANN for the opportunity to comment on the draft 
ICANN Strategic Plan 2008 to 2011.
 
Nominet representatives have appreciated being consulted during the 
creation of the draft plan and will continue to encourage other ccTLD 
managers to be more involved in the strategic plan process. We make the 
following comments on the draft strategic plan:

Vision 
We support Raimundo Beca?s comments concerning the need for a shared 
vision for ICANN - a statement that describes the long-term goal and 
direction of the organization. The vision statement, together with the 
mission and values, could then combine to form the foundation of the 
strategic plan and make clearer the future direction of ICANN.

Key Challenges & Opportunities
The current draft contains a good analysis of the key environmental and 
organisational challenges for ICANN that has been developed by the 
community. Firstly, it should be acknowledged that it might not be 
possible to fully address each challenge during the life of the plan. 
Secondly, it is sometimes difficult to track where each challenge is dealt 
with under the strategic priorities, or within in the strategic plan 
itself. For some of the challenges, this is reasonably obvious. But for 
others, it is not obvious. In addition, the actions or initiatives in the 
plan do not always address the challenge that has been identified.

Strategic Priority 1 ? Implementation of IDNs and new gTLDs 
The challenge of significant increases in the volume of policy and 
management work that needs to be done (key organisational challenge iv) is 
directly relevant to this priority, but only appears to have been 
reflected in paragraphs 2.3 and 2.4, which refer to increases in staff for 
new gTLD related work. The challenge of successfully managing the timely 
development of policy in a largely volunteer organisation (key 
organisational challenge v) is also directly relevant here. This is partly 
identified in paragraphs 1.2 and 1.6, which refer to the co-ordination and 
support of supporting organization and advisory committee work. However, 
if this work is to be completed in a timely manner, it may well also 
require additional resources. In addition, the management load that will 
result from the parallel development and introduction of both IDNs and new 
gTLDs, together with other challenges, should not be under estimated.

Strategic Priority 2 ? Continuing to improve core operations 
Nominet strongly supports continued improvements to the IANA service and 
the automation of IANA processes to enhance productivity and efficiency. 
However, we consider the previous strategic plan priority title, of 
Excellence in Operations, was a more stretching and appropriate title, 
which better encapsulated the aspirations of both IANA and its 
stakeholders.

Strategic Priority 3 ? Strengthening ICANN?s Multi-stakeholder model 
We support the aim of continuing to encourage ccTLD participation in the 
ccNSO (paragraph 27). In our comments on the previous Strategic Plan, we 
undertook to assist with this task, and I now Chair the ccNSO Working 
Group, which aims to improve participation in both the ccNSO and regional 
organizations. However, the sub-paragraphs under this section (27.1-27.3) 
do not appear to fully address the challenge, in that they do not include 
the development of improved two-way communications with ccTLDs and the 
potential contribution of the ICANN Fellowship scheme. In terms of the 
sub-paragraphs:

27.1 The current text does not appear to make complete sense. Many ccTLDs 
agree with the Government Advisory Committee principle of subsidiarity ? 
i.e. that ccTLD policy should be set locally, unless it can be shown that 
the issue has global impact and needs to be resolved in an international 
framework. So we suggest that this should be re-worded to say: In 
partnership with the ccNSO, identify areas of concern that have global 
impact and which therefore need to be resolved in an international 
framework. Develop and implement plans for broad-based discussion of these 
concerns and offer appropriate support.

27.2 We suggest that this should also recognise the opportunity to work 
with the regional organisations in the delivery and co-ordination of 
regional workshops.

Finally, this strategic priority also includes the reviews of the ICANN 
structures.  It is suggested that the paragraphs relating to the 
Nominating Committee and Board (paragraphs 31 & 32) would be better placed 
under priority 5: Strengthening accountability and governance. Paragraph 
32 refers to the Board review and possible recommendations to further 
improve the effectiveness of ICANN?s Board. In our view, one of the key 
challenges/risks going forward will be ICANN?s ability to recruit Board 
members with sufficient levels of skills and expertise to be able to 
provide effective oversight and leadership, who are also willing and able 
to dedicate sufficient time to this role as a volunteer. This is a 
potential risk to ICANN?s future success and therefore should be 
recognised in this paragraph.

Strategic priority 5 ? Strengthening Accountability and Governance
Paragraphs 50-54 cover the Joint Project Agreement and assume that a 
transition to private sector management will take place within the 
lifetime of the plan. In our view the plan does not sufficiently address 
the issues of oversight and accountability that will need to be resolved 
if this transition is to occur. The GAC paper on Definitions of 
Accountability in the ICANN Environment is an excellent contribution to 
this challenge.

In terms of transparency (paragraph 55), it is acknowledged that much has 
been done to improve performance in this area. Indeed, it is possible that 
the quantity of detailed information being produced will make it difficult 
for some stakeholders to keep up to speed with issues. It is therefore 
suggested that this section should include the development of improved 
multi-level communications with higher-level summaries being available to 
all stakeholders, middle level information for those more interested in an 
issue and more detailed information available for those who desire it.

In our comments on section 3, we suggested that the paragraphs regarding 
the Nominating Committee and the Board should be moved to this section, as 
in our view they are more relevant to accountability and governance. Also, 
we note that paragraph 55.2 proposes the embedding of management operating 
principles that include governance best practices. Although we have no 
specific concerns regarding current practices, we support this intent and 
suggest that it should be extended to the embedding of corporate 
governance best practices for the Board.

I do hope that this feedback will be of use to you as you develop and 
implement the Plan and I look forward to playing a part in the development 
of the strategic plan 2009-2012.

Regards,
Lesley