ETSI comments on the Draft TLG Report

[Julian Pritchard <julian.pritchard@xxxxxxxx>]

General comments:
The draft Report totally ignores ETSI's activities as a Global SDO.
The draft Report totally ignores the history of ETSI's involvement with ICANN.
The TLG appeared in the ICANN reform as the place where standardization 
organizations, formerly represented in the Protocol Supporting Organization 
(PSO) and the Domain Names Supporting Organization (DNSO), continued having a 
role in ICANN after the abolishment of the PSO. Under the PSO rules members had 
to be considered as 'international', and the "full" members had to include 
individuals or companies primarily located in at least three different regions 
and at least two different countries within each of those regions.  ETSI's wide 
international membership base (today over 700 members from more than 60 
countries) was more than sufficient for accreditation as "International" rather 
than "Regional" in the ICANN context.  In the DNSO, ETSI was present via CORE, 
the Committee of Registrars, of which ETSI was a founding member.  ETSI was 
also responsible for the creation of the CORE Database used for DNS 
registration.

The TLG allows ETSI to participate in a formal way to ICANN.
ETSI has supported ICANN for a long time, and the participation in the TLG 
shows this commitment to the support.
Technical Liaisons have an important role to ensure that ICANN has the right 
balance in technical knowledge.  The ICANN Board seat allows ETSI to bring 
technical understanding to the ICANN Board deliberations (from the Telecom 
ecosystem perspective).  The ICANN Board liaison provides valuable information 
back to ETSI members which helps to ensure technical compatibility issue and 
interoperability.

Specific comments (numbered with respect to the draft TLG Report):

4.2.2 Institutional relationships are not reciprocated
Reciprocity was never mentioned before and has never been requested by ICANN so 
it is rather strange that it now appears as an "issue".  In fact, there is a 
form of reciprocity as the ICANN CEO and the ICANN Board Chairman routinely 
receive personalised invitations to attend ETSI General Assemblies (as a result 
Roberto Gaetano attended a number of times when he was ICANN Board Vice-Chair).
It is doubtful that ICANN participation to the ETSI Board would bring any value 
to ICANN.  However, ETSI participation to ICANN brings technical understanding 
to the ICANN Board deliberations (from the Telecom ecosystem perspective).

4.2.3 Concern around conflicts of interest and lack of role clarity
There has never been any discussion, accusation nor any suggestion that there 
could be a conflict of interest situation related to the ETSI TLG 
representatives. The ETSI role is quite clear; e.g. to provide technical 
understanding and clarification.

5.1 Overview and key issues
ICANN governance participation privileges are not reciprocated by TLG 
organizations.
Same response as for 4.2.2 above:
Reciprocity was never mentioned before and has never been requested by ICANN so 
it is rather strange that it now appears as an "issue".  In fact, there is a 
form of reciprocity as the ICANN CEO and the ICANN Board Chairman routinely 
receive personalised invitations to attend ETSI General Assemblies (as a result 
Roberto Gaetano attended a number of times when he was ICANN Board Vice-Chair).
It is doubtful that ICANN participation to the ETSI Board would bring any value 
to ICANN.  However, ETSI participation to ICANN brings technical understanding 
to the ICANN Board deliberations (from the Telecom ecosystem perspective).

ICANN is harmed by conflicts of interest and lack of role clarity of TLG 
members.
Same response as for 4.2.3 above:
There has never been any discussion, accusation nor any suggestion that there 
could be a conflict of interest situation related to the ETSI TLG 
representatives. The ETSI role is quite clear; e.g. to provide technical 
understanding and clarification.

5.2 The TLG is atypical and not well understood
QUESTION: Does the TLG provide a unique source of qualified technical Board 
members?
The suggestion that the same delegates would appear via NONCOM if the TLG is 
closed is a false assumption.  Without the pressure that the ETSI Board puts on 
its membership to offer candidates due to our TLG obligations these people 
would probably never even appear on the NOMCOM radar screen.

5.3 The TLG is not used as intended
QUESTION: Are W3C, ETSI, and ITU‐T the right organizations to be represented on 
the TLG?
RECOMMENDATION 3: If the TLG is not dismantled, consider removing 
region‐specific representation from the TLG, specifically ETSI.
The text in this section of the report show a total lack understanding of ETSI 
and it's global role.  Characterizing ETSI as a Regional SDO is wrong in this 
context.  In the ICANN context ETSI is operating as a "global" SDO representing 
the interests of 700+ members from 60+ countries rather than in it's European 
ESO-role.  ETSI is the birth place of GSM and the home of the 3GPP secretariat 
therefore ETSI also brings the technical knowledge from the mobile sector to 
ICANN and in addition, the work in ETSI TC TISPAN supplementing the IETF work 
is of significant importance.  ETSI is primary a technical organization and 
provides Technical Specifications to support the Internet infrastructure!  See 
also, the comment above on the history ETSI's involvement with ICANN and 
accreditation as an International body under the PSO rules.

QUESTION: What structural and operational measures can be imagined to enhance 
the effectiveness of the TLG?
Although the TLG is not allowed to hold meetings nor to perform internal 
consultations a certain amount of co-ordination is required to ensure that the 
rotating seats on the ICANNN Board and NOMCOM are filled with suitable 
candidates from the appropriate TLG organizations.  The Governance Support 
Director has provided that service since 2004, acting as a co-ordination point 
and issuing reminders to the ETSI Board, ITU-T TSB Director, and W3C in due 
time, and also maintaining contact with the ICANN Board and NOMCOM 
Secretariats.  If the TLG continues then this coordination function should 
either be formalised or clearly taken-over by the ICANN Secretariat.  ETSI is 
more than happy to continue offering this co-ordination function.

5.4 ICANN governance participation privileges are not reciprocated by TLG 
organizations
Same response as for 4.2.2 and 5.1 above:
There was never any request for reciprocity, so it is rather strange that it 
now appears as an "issue".  In fact, there is a form of reciprocity as the 
ICANN CEO and the ICANN Board Chairman routinely receive personalised 
invitations to attend ETSI General Assemblies.  ETSI provides ICANN with a 
valuable resource in the form of delegates to the ICANN board and the NomCom, 
this person is paid by the ETSI member he/she works for which costs their 
company time and real money. So, in practical term ETSI is investing to ICANN.  
Within ETSI ICANN is treated in the same way as if ETSI & ICANN had signed a 
formal Memorandum of Understanding (even though no such paper exists in this 
case).

5.6 ICANN is harmed by conflicts of interest and lack of role clarity of TLG 
members
There has never been any discussion, accusation nor any suggestion that there 
could be a conflict of interest situation related to the ETSI TLG 
representatives.

These comments have been endorsed at the ETSI Board meeting #80 on 5 November 
2010.

Julian Pritchard
Governance Support Director & ETSI Board Secretary
ETSI (European Telecommunications Standards Institute)