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h1. ALAC Statement on the Draft 2011-2014 Strategic Plan - Version 0.01


h3.

h2. Intro

placeholder for text to go here


h2. {color:#003366}{*}General Comments and *{color}{*}Comments on Process and Structure*


h3. {color:#003366}{*}ICANN Planning Cycle{*}{color}

{color:#000000}The current planning cycle is designed to involve constituencies in the planning process at an earlier stage than it used to be. The new timing, as explained on the graphic supplied by ICANN, shows a FY12 first comment period on Nov 10 on the Strategic 2011-2014 Strategic Plan, then a second comment period in February 2011 for the FY12 Framework, and finally a FY12 Adopted Budget comment period in May 2011.{color}

{color:#000000}This will require adjustment of At Large planning cycle to become in sync with the FY12 development cycle.{color}

{color:#0000ff}EURALO input=>{color} {color:#0000ff}This year has seen a new calendar for the development, presentation and feedback process of the ICANN Strategic Plan.{color}

{color:#0000ff}With the introduction of IDNs, ICANN has truly demonstrated its efforts towards local communities. At Large also needs to reflect sensitivity towards its local communities, especially since it draws among the capabilities and capacity of a volunteer base. The new published planning phase diagram shows comment periods in November 2010, February 2011 and May 2011.{color}

{color:#0000ff}Nonetheless, the current Draft ICANN Strategic Plan was published at the end of November, opening a comment period spanning the month of December 2010 and the early part of January 2011. The enabling environment required to obtain quality input from communities worldwide must be times in regards when a volunteer community can be mobilised.{color}

{color:#0000ff}Thanks to busy religious and festive calendars giving rise to holiday periods for a significant percentage of the world's population, the months of December, January, July and August are not such times. On the other hand, Spring is good; Autumn is good. The calendar for comments as important as those towards the ICANN Strategic Plan would therefore need to be studied further and amended appropriately in order to have full community feedback.{color}

h3. {color:#003366}{*}New Plan Goals{*}{color}

{color:#000000}At Large fully supports the new plan Goals of re-organise objectives to distinguish areas of control vs. influence as well as bringing in measureable objectives. It would be useful if ICANN kept track of those objectives and we are looking forward to see such tracking take place, alongside performance evaluation reinforcing accountability.{color}

h3. {color:#003366}{*}Response to Community Input{*}{color}

{color:#000000}At Large is pleased to see the new process for engaging community input at an earlier time, and amending the plans according to the first round of such input. It is through such dialogue with the whole community that processes will attain better accountability and legitimacy with the community as a whole. In our view, this reinforces the notion of bottom-up process in ICANN.{color}

h3. {color:#003366}{*}Plan for getting Board Approval{*}{color}

{color:#000000}The new plan for getting Board Approval is a significant improvement over the process it replaces. The consultations with Working Groups and Constituencies have engaged Constituencies immediately and helped bring ownership of the plan closer to the edges. At Large hopes that this process will be upheld in future Strategic Plan cycles and even reinforced through enhanced collaboration between itself and the planning team. We will strive to ensure better communication with At Large Structures (ALSes) so as for the edges of the At Large Organisational Structure to have a greater voice and so as to enhance the process of global involvement in this novel governance model.{color}

h2. Comments on Content Regarding the Four Strategic Focus Areas:


h3. General Comments

{color:#008000}LACRALO input=> LACRALO wishes to commend ICANN on the "stream-lined" approach undertaken to develop the draft 2011-2014 Strategic Plan.{color}
{color:#008000}We stress the value of the equal multi-stakeholder partnership among business sectors, Governments and end-users, with the ultimate goal to increase of end users’ participation.{color}


{color:#008000}Two suggested general improvements\-{color}
{color:#008000}● The language availability of documents/slides used for stakeholder consultations in at least Spanish and French.{color}
{color:#008000}● Additional slides showing changes from the previous Strategic Plans to the draft Strategic Plan for each of the four pillars (DNS stability and security, Consumer choice, competition and innovation, Core operations including IANA, A healthy internet ecosystem) would improve the accessibility and review of the information provided.{color}

{color:#0000ff}EURALO input=> EURALO fully support the initiatives described in the ICANN Strategic Plan for 2011-2014.{color}

{color:#0000ff}It is the view of several ALSes that the document contains a good deal of stable material which has improved year on year, and this year's version continues in the same direction. This is appreciated by ALSes.{color}

{color:#ffcc00}NARALO input=> As ICANN is known to lack strategic purpose this comment attempts to remove what can't usefully be strategic. An afterward states the author's recommendations for the organization's current strategic plan elements.{color}

h3. 1. DNS stability and security

\\

{color:#800080}{*}ALAC input => *{color}DNS stability and security is of primary importance for end users who wish to use an Internet that is as reliable as can be. Any focus by ICANN to enhance stability and security is welcome.

The mention of IPv6 roll-out, adoption and engagement, at the three levels (Community Work, Strategic Projects and Staff Work) is a positive and welcome development.

However we are concerned that, as written, the Strategic Plan is preempting the outcomes and recommendations of the Joint DNS Security and Stability Analysis Working Group (DSSA--WG)  with the sentence in this section of the document,  " ICANN will follow the lead of its community working groups to develop an approach to the establishment of solutions such as coordination of an emergency response team (DNS CERT) to address one of the issues of Internet security."  ALAC recommends this text be deleted  and the paragraph 4 of this section of the document would then read. _"_{_}Increase international participation in unique identifier security.  Attacks on the unique identifier system can come from anywhere around the globe.  Strong international security systems and skills are first line deterrents to bad behavior.    Staff and community work will focus on global security outreach and collaboration with Regional Internet Registries (RIR) operators to improve overall security.   ICANN will follow the lead of its community working groups_ _to to develop an approach to the establishment of solutions to address{_}_ issues_ _of Internet security.   Also, community work needs to facilitate the acceptance of internationalized registration data in the Whois database."_


{color:#ff6600}AFRALO input=> AFRALO acknowledges that the stability and security of the DNS is an important element for ICANN and the global internet users. Therefore, it thinks that ICANN should prioritise the support for the implementation of DNSSEC. It highly appreciates the ICANN’s initiative to perform training for TLD operators.AFRALO argues that ICANN should come up with a plan for Disaster Recovery and Business Continuity for its own operations.<end>{color}

{color:#ff0000}APRALO input=>{color} {color:#ff0000}APRALO notes that introduction of IDNs could cause new security risks to  DNS (such as phishing) and thus fully agree with ALAC's statement that  ICANN should increase international participation in unique identifier  security. In addition, APRALO believes that, without prejudice to the  expertise of technical community, ICANN should facilitate the  participation of user community, particularly IDN language community, in  development of security measures and policies.{color}

{color:#ff0000}ICANN should prioritize its efforts towards supporting regional and local efforts for the promotion of SSR of the unique identifier systems, instead of duplicating or commandeering its centralization.&nbsp; At this time, ICANN's role shall be best served, as a coordinator and facilitator, by directing its resources and funds towards regional and local efforts in the promotion of DNS security as well as IPv6 along with IP security.&nbsp; This includes resources and funds for RIRs, ALSes and other appropriate organizations that have initiated work on SSR as well as to support others that have not to get started.&nbsp; ICANN's priority should be to support regional and local organizations to become leaders in SSR promotion rather than followers to ICANN.{color}

{color:#0000ff}EURALO comments->{color}

{color:#008000}LACRALO comments->{color} {color:#008000}Under “cooperative TLD training in developing countries”, we are supportive of any such training to involve as many stakeholders as possible including At-Large Structures.{color}

{color:#ffcc00}NARALO comments \->{color} {color:#ffcc00}This section contains four strategic objectives:{color}

{color:#ffcc00}\(i) Maintain and drive DNS uptime,{color}

{color:#ffcc00}(ii) Increase security of the overall systems of unique identifiers,{color}

{color:#ffcc00}(iii) Increase international participation, and{color}

{color:#ffcc00}(iv) Coordinate DNS global risk management.{color}

{color:#ffcc00}\(i) The first strategic objective is unclear whether the 100% DNS uptime refers to the A-M rootservers, or to the{color} {.arpa,.mil,.edu,.gov,.int, .com,.net,.org} {color:#ffcc00}authoritative gTLD servers{color}
{color:#ffcc00}which pre-exist ICANN, or to the authoritative gTLD servers created by ICANN, or to authoritative ccTLD servers, or to AS112, or to the recursive servers operated by content and access network operators, or ... nor where any measurement of "uptime" might be conducted.{color}

{color:#ffcc00}A strategic objective which is incomprehensible is usually the sign that the entity lacks internal clarity on the subject matter and is unable to prioritize and select achievable objectives.{color}

{color:#ffcc00}The A-M rootservers are fine, there is no urgent issue there. The{color} {.arpa,.mil,.edu,.gov,.int, and .com,.net,.org} {color:#ffcc00}authoritative gTLD servers are fine too, though the .mil operations could be improved, and the .gov operator is scheduled to transition. The{color} {.biz,.info,.name,.pro and .aero,.coop,.museum} {color:#ffcc00}authoritative gTLD servers are acceptable, problems exist but not at the level of some strategic effort that has to put "change" before "stability". The{color} {.asia,.cat,.jobs,.mobi,.travel} {color:#ffcc00}authoritative gTLD servers are also acceptable, problems exist but not at the level of some strategic effort that has to put "change" before "stability".{color}

{color:#ffcc00}That leaves the ccTLDs, for which no "strategic goal" is possible now that the botched attempt to force ccTLD operators to enter into contracts or be unable to update their entries in the IANA root zone is an unpleasant memory, AS112, and recursive resolvers widely known to be providing synthetic (monitized) returns for most broadband users in North America \-\- a situation that does call for a strategic object, following through on the Board's Sydney Resolution on NXDOMAIN Substitution (DNS Wildcard and Similar Technologies).{color}

{color:#ffcc00}A strategic goal of reducing incorrect synthesized DNS responses by some measurable amount would be credible, and useful. Absent that, this is just a bag holding secondary objectives \-\- continuity and v6.{color}

{color:#ffcc00}(ii) The second strategic objective errs significantly.{color}

{color:#ffcc00}First, if 30 ccTLD operators in developing countries sign their zone, that is a poor predictor of whether when the key's for those signed zones expire that the 30 ccTLD operators in developing countries, who are generally technical assistance recipients through the Network Resource Startup Center, that key rollover will be conducted successfully.{color}

{color:#ffcc00}Second, developing countries have autonomous agendas, and if ICANN is flirting with returning to the unhappy model of "enter into contracts or else" by placing the Marina del Rey agenda for zone signing ahead of the autonomous agendas of developing countries, there will be issues. ICANN pushed cost on ccTLD operators in developing countries by declining to pick up the rather small costs of their participation in the Conficker .C response. There was some real bitterness about John Crain's communicating, and the color of an ICANN endorsed urgent communication to burn local time and money preventing bad things from happening to North American and European end users through spam and/or{color}
{color:#ffcc00}maleware targeting by the .C enabled users of the Conficker platform.{color}

{color:#ffcc00}Third, fixing .com comes a bazillion years ahead of fixing .name, which is larger than all 22 ccTLD operations where Arabic is the primary spoken language, or all of Africa, less South Africa, or ...{color}

{color:#ffcc00}If this were a proposal to improve the performance of some system by working on code paths visited less than 1% of the time, the eager to optimize coders without a clue would be given other responsibilities.{color}

{color:#ffcc00}The real item to work on here is the routing (not "resource") public key infrastructure, securing BGP and detecting AS Prepending attacks, which mercifully appear at present to be fatfinger events, not information operations by motivated and competent parties pursuing rational economic or other policy goals.{color}

{color:#ffcc00}The buried lede is the most important and overlooked task, and this, not uptime, is what is important.{color}

{color:#ffcc00}Fortunately, the RPKI infrastructure is being rolled-out in the ARIN region, and has been rolled-out in other regions.{color}

{color:#ffcc00}(iii) The third strategic objective makes reference to the "DNS-CERT".{color}

{color:#ffcc00}Please see my public comments archived in the stratplan-2010@icann.org{color}
{color:#ffcc00}mailbox at:{color} {color:#ffcc00}[http://forum.icann.org/lists/stratplan-2010/msg00027.html]{color}

{color:#ffcc00}The addition of the IDN version of the perenial WHOIS foodfight is a mistake. Whatever the value of adding UTF-8 or local encoded data into WHOIS output may be, it isn't DNS stability and security. This kind of junk detracts from the real issues.{color}

{color:#ffcc00}(iv) The fourth strategic objective fails to mention the Conficker .C facts, so the most recent "global risk management" event of import is overlooked. This is unfortunate as there really is a lot to be learned from the response, even to a non-event, about cost, timeliness, and accounting.{color}

{color:#ffcc00}Over all, there really is no reason why most of the ccTLD operators outside of North America and Europe should pay any attention to ICANN's DNS stability and security StratPlan component, and that is not in the public interest of North American internet users, who do not need ICANN to be ignoring development goals for false objectives and bandaids.{color}

h3.


h3. {color:#003366}{*}2. Core Operations including IANA{*}{color}

{color:#800080}{*}ALAC input =>*{color}{color:#000000}&nbsp;*&nbsp;*At Large supports the decision of ICANN to submit a proposal for the IANA contract renewal based on ICANN’s track record and other factors including the confidence that ICANN’s multi-stakeholder model of bottom-up governance is a guarantee of good standing with regards to core operations.&nbsp;{color}

{color:#000000}The aim of improving the ongoing efficiency and effectiveness of policy development and implementation processes and the multi-stakeholder model that engages the community is fully supported by At Large. Furthermore, At Large agrees with the GNSO initiative to improve the PDP and also encourages and supports additional initiatives.{color}

{color:#000000}The continuous improvement process towards operational excellence is very welcome and At Large fully supports ICANN’s engagement with the technical community including the IETF and root server managers.&nbsp;{color}

{color:#ff6600}AFRALO takes positive note of the ICANN willing to provide the international Internet community a transparent and collaborative model for root server operations.{color}

{color:#ff6600}It acknowledges the ICANN commitment to improving the efficiency and effectiveness of policy development and implementation processes and the multi-stakeholder model that engages the global community.{color}

{color:#ff0000}APRALO comments->{color} {color:#ff0000}APRALO agrees with ALAC that IANA contract should be renewed based on  track record and take into account ICANN's independence and internationalization.{color}

{color:#000000}&nbsp;{color}

{color:#0000ff}EURALO comments->{color}

{color:#000000}&nbsp;{color}

{color:#008000}LACRALO comments->{color} {color:#008000}LACRALO notes the presence of “IANA request processing” and wishes to suggest an item under community work or staff work relating to the accountability and transparency of ccTLD redelegation requests sent to IANA\-{color}

{color:#008000}● ccTLD redelegation requests are not public. Hence not all members of the local internet community ({color}{color:#008000}[http://blog.icann.org/2009/09/local-internet-communities/]{color}{color:#008000}) may be informed{color}
{color:#008000}in the discussions related to their ccTLD redelegation.{color}

{color:#000000}&nbsp;{color}

{color:#ffcc00}NARALO comments \->{color} {color:#ffcc00}This section contains four strategic objectives:{color}

{color:#ffcc00}\(i) Continued flawless IANA operations,{color}

{color:#ffcc00}(ii) L-Root operational excellence,{color}

{color:#ffcc00}(iii) Efficiency and effectiveness of operations and{color}

{color:#ffcc00}(iv) Strengthen international operations and presences.{color}

{color:#ffcc00}\(i) The first object posits the utility of the EFQM model to IANA operations, and this simply doesn't jib with my experience consulting on the IANA function reporting project in 2007. Further, the SLAs to which the EFQM might, or might not be relevant to originate from the IETF for protocol assignments. While the epoch in which the IANA function was administratively restrained from timely responses to requests for zone file updates from ccTLD operators until those ccTLD operators entered into a contract is now an unhappy memory, this too is an unlikely source of SLA commitments which could benefit significantly by the application of the EFQM model.{color}

{color:#ffcc00}If ICANN is to secure a renewal of the IANA contract, it is at least as likely that the merits of ICANN's renewal bid are the qualitative services necessary to manage a mixed signed-and-unsigned zones, and the qualitative services necessary to introduce RPKI, as the quantitative execution of a formal quality model indifferent to the current, and future services performed by the IANA function.{color}

{color:#ffcc00}(ii) The second objective pursues a mission outside of ICANN's core purpose. Running the L-Root is about as peripheral to ICANN's purpose as being an ICANN Accredited Registrar is to AOL or France Telecom or British Telecom. It simply isn't important.{color}

{color:#ffcc00}Next, the other root servers are run by Verisign-A, USC-ISI, Cogent, UMaryland, NASA, ISC, DISA, BRL, Autonomica, Verisign-J, RIPE NCC, and WIDE. How on earth is ICANN going to "lead by example" or "be recognized as a top-tier root zone manager"? What motivates ICANN to embark on a (probably futile) pecking order mission to provide clue to{color}
{color:#ffcc00}any of, let alone all of, the other root server operators?{color}

{color:#ffcc00}A reasonable strategic objective would be to find a qualified operator for the L-Root that would meet some unmet policy goal such as geographic diversity and schedule the transition so that ICANN could get out of registry operations and focus on its core mission.{color}

{color:#ffcc00}(iii) The third objective I still don't believe. What on earth does the IANA function have to do with the Policy Development Process the Names Council has adopted? The suggestion that the execution of the IANA functions services deliverables to the GNSO's PDP, pre\- or post-reform, requires strategic attention indicates that either due to errors in wordsmithing, or leadership (of ICANN and the IANA) changes, that the relationship, never very significant, between the original DNSO, now GNSO, and the IANA, is not understood.{color}

{color:#ffcc00}(iv) The fourth objective mentions, inter alia, engagement with the IETF and the root server operators. Please add the RPKI communities of each of the RIRs.{color}

{color:#ffcc00}(v) The fifth objective is without quantifiers. What are the strategic goals for financial controls, capacity, etc.?{color}



h3. 3. Consumer choice, competition and innovation

{color:#993366}{*}ALAC input => &nbsp;*{color}{*}need to refer to the joint work outlined in the Board resolution from Cartagena re the definitions &nbsp;work &nbsp;to be done here &nbsp;TEXT REQUIRED*


comments on the &nbsp;ICANN-identified stategic objectives:

1. More TLDs available in multiple languages (IDNs)

2. Increase regional participation in the industry

3. Mitigate Malicious conduct

4. Foster industry innovation

5. Promote fair opportunities

6. Implementation & deployment of the IDNS protocol to ensure IDNs operate as expected

&nbsp;ICANN At Large-identified Strategic Objectives

{color:#800080}{*}ALAC input => &nbsp;&nbsp;*{color}At Large re-iterates its comments made in previous years. We are very pleased that IDNs are providing consumer choice and hope that the new gTLD programme will be beneficial to healthy competition but also to an increase in regional participation in the industry. Choice does not only come from a select few regions of the world, but from having a local partner, accessible locally and understanding local cultures.

At Large supports the strategy defined in the document fully, with a special mention for promotion of local communities. It is our wish that the new gTLD programme benefits local communities directly.

Also emphasised is the notion of mitigating malicious conduct. At Large is ready to help drive the process of developing a Registrants Rights Charter in collaboration with the rest of ICANN.

{color:#ff6600}AFRALO input=> AFRALO argues that in line with one of ICANN’s core values, which is introducing and promoting competition in the delegation of Top Level Domains where practicable and beneficial in the public interest, ICANN should make the application fee for new TLDs within the reach of each applicant alike. Levying high application fees for all applicants creates the disparity between the have and have-not’s. Therefore, we urge ICANN to review the applicant guide book to reflect the almost unanimous wish regarding the application fees expressed in all public comments on the previous versions, in the Working Group 3 (at-large summit, Mexico) report approved by ALAC, and in the JAS working group milestone report.{color}

{color:#ff6600}We note the positive initiative to provide effective program management for the successful deployment of IDNs trough the new gTLD and ccTLD programs.{color}

{color:#ff6600}Conducting education and training programs in partnership with ISOC, local operators and local internet communities is an excellent approach. However, AFRALO believes that part or all of those programs could and should be conducted by ICANN constituencies, such as At-Large structures and regional organizations for the part related to Internet users.{color}

{color:#ff0000}APRALO input=>{color} {color:#ff0000}APRALO agrees that introduction of new gTLDs and implementation of IDNs  both in gTLDs and ccTLDs would saliently serve the purpose of consumer  choice, competition and innovation. After more than 10 years' technology  and policy development, it is highly time for ICANN to take action  timely.{color}

{color:#ff0000}The implementation of IDN TLDs, including IDN ccTLDs as well as IDN gTLDs, is of great importance and urgency to many of the language communities in Asia Pacific.&nbsp; ICANN should follow its commitments set forth in the AOC and prioritize efforts to implement complete IDN TLDs policies and mechanisms that serves the most needed IDN communities.&nbsp; These include the implementation of Single Character IDN TLDs for non-alphabetic scripts and the implementation of variant management mechanisms for the root for those languages which have a fully developed and proven policy-driven framework utilizing existing DNS technologies.&nbsp; While the former serves as a critical competitiveness equalizer for single word TLDs in alphabetic scripts, the latter is a critical measure for the socio-technical stability of the Internet.{color}

{color:#ff0000}The time has come when the benefits and criticality of introduction of IDN gTLDs grossly out-weigh the costs of further delaying and clouding such with issues concerning the addition of more ASCII gTLDs.{color}


{color:#0000ff}EURALO comments->{color}

{color:#000000}&nbsp;{color}

{color:#008000}LACRALO comments->{color} {color:#008000}LACRALO is convinced that both financial and professional support shall be required to enable disadvantaged communities to effectively participate in the new gTLD ecosystem towards empowering consumer choice, competition and innovation.{color}

{color:#008000}As a consequence, LACRALO is eager for the ICANN community fully embrace the initiative vested in the Joint Applicant Support Working Group (JAS WG), that seeks to find and propose ways the ICANN community may provide effective support that will enable participation of these communities.{color}

{color:#000000}&nbsp;{color}

{color:#ffcc00}NARALO comments \->{color} {color:#ffcc00}This section contains five strategic objectives:{color}

{color:#ffcc00}\(i) More IDN TLDs,{color}

{color:#ffcc00}(ii) Increase Regional participation in the industry,{color}

{color:#ffcc00}(iii) Mitigate malicious conduct,{color}

{color:#ffcc00}(iv) Foster industry innovation, and{color}

{color:#ffcc00}(v) Promote fair opportunities.{color}


{color:#ffcc00}\(i) When CNNIC turned on its name server constellation the ground work for the .中国, .公司, .网络 and .政务 and .公益 IDNs was laid. That the ground work lagged behind elsewhere is water under the bridge. If the principle of "consumer choice" is to be meaningful, it is consumers who's choices inform policy makers, not producer choices. At{color}
{color:#ffcc00}present more than a million users use these IDNs. The strategic plan should place their interests ahead of the legacy operator interest in capturing lucrative markets.{color}

{color:#ffcc00}It is impossible not to observe in passing that the strategic goal of "more languages and cultures" is subordinate to the strategic goal of a single application process, which as has been observed elsewhere, benefits “a group of participants that engage in ICANN's processes to a greater extent than Internet users generally”.{color}

{color:#ffcc00}(ii) Continued financial support for the NSRC's IROC, AROC, SROC offerings is a reasonable goal.{color}

{color:#ffcc00}(iii) The "malicious conduct" construct has, thus far, avoided mention of the causes for operational capability of actors that engage in conduct characterized as "malicious". It is primarily an individual morality construct, carefully omitting the business models which create the financial incentives as well as the technical means for "malicious conduct" on a global scale.{color}

{color:#ffcc00}Signing zones as a consequence of the discovery that cache poisoning could be accomplished in seconds is a reasonable response to the discovery of a economic development in attack cost.{color}

{color:#ffcc00}Ignoring the non-adoption of BCP-38 and other forms of industrial externalization of costs, to ccTLD operators in the Conficker .C case, is not a reasonable response to a long-standing problem.{color}

{color:#ffcc00}Morality as policy is fine on TeeVee. It is a profoundly dull tool for network policy making.{color}

{color:#ffcc00}(iv) No comment.{color}

{color:#ffcc00}(v) Reference to the area of work undertaken by the Joint Applicant Support Working Group is gratifying.{color}


h3. 4. A healthy Internet eco-system

At Large fully supports the recommendations contained in this sub-section. As a reminder, At Large is a core constituent of each one of the core strategic objectives outlined in this section. In particular, we welcome Internet Governance education and would urge ICANN to consider making better use of the power and outreach of At Large’s constituency organization of Regional At Large Organisations (RALOs) and At Large Structures (ALSes) present in over 80 countries around the world.



*One unified, global internet*

 {color:#ffcc00}NARALO input=> The first section contains the alarming possibility that the overwhelming contributions of volunteer time, paid staff, and expended resources committed to the new gTLD program since 2006 have only a "potential" to realize a single new community-based or public interest registry.{color}

{color:#ffcc00}Leaving the merits of forming corporate vision and mission from a sample of semi-random responses to a social networking technology that amounts to little more than an IRC client (who's operator collects and monitizes personally identifiable information about its users), there are the implicit limitations of this "vision".{color}

{color:#ffcc00}Nearly all of ICANN's contractual counter-parties to registry agreements are legally domiciled in the North American Region, and with the exception of name server constellations, are operationally contained in the North American Region.{color}

{color:#ffcc00}The same is true of the approximately six hundred of its (wildly shell-registrar inflated) nine hundred counter-parties to registrar agreements, four of which alone account for 50% of all gTLD registration.{color}

{color:#ffcc00}It is in the public interest that public policy is informed by data and both the failures, and the successes, of policy choices, can be discerned and outcomes understood in terms of causes and effects.{color}

{color:#ffcc00}Legal barriers particular to the North American Region's legal culture prevent research access to operational network infrastructures for reasons of economics, ownership, and trust (EOT).{color}

{color:#ffcc00}These must be reduced if policy making is to be informed by knowledge rather than by belief.{color}

{color:#ffcc00}For reasons of operational necessity a constellation of name servers was activated by CNNIC in November, 2001. Since early 2008 this constellation of name servers has provided service to more users in Asia than the original constellation of name servers provides users in North America.{color}

{color:#ffcc00}The Vision Statement should be amended to correct the impression that some more fundamental management problem exists than managing the sources of policy errors which have necessitated the existence of the CNNIC root server constellation, and the continued necessity for divergence between these two root systems.{color}

{color:#ffcc00}It is not in the public interest for North American internet users to be unaware that errors of judgment have, and may further partition "the internet".{color}

{color:#ffcc00}These two changes to the Vision Statement may be expressed as: "Informed by data, divided only by necessity."{color}





*Building stakeholder diversity*

{color:#800080}{*}ALAC input =>*{color}

{color:#ff6600}AFRALO agrees that continued internationalisation of ICANN is crucial to maintaining a single, global interoperable Internet and a single Internet zone file used globally.It takes positive note that ICANN will formalize a cross-stakeholder model, and will also formalize input from the At-Large community into Board discussion.While recognizing the ICANN effort for a multilingual working environment, AFRALO considers that for an international organization, more commitment is needed to translate the most of the ICANN documents, and to implement simultaneous interpretation for the most of the meetings (face to face or telephonic). This interpretation is urgently needed for the fellowship program which is now restricted to the English speakers only.{color}

{color:#ff0000}APRALO comments->{color} {color:#ff0000}APRALO believe that individual users community has been developing in  the multi-stakeholder, internationalized and diversified environment and  its influence can be felt in a couple of policy-making processes. But  comparing with the private sector and governments, users community has  still great potential for building a more healthy eco-system in ICANN.  ICANN may wish to take systematic measures, including budget planning,  to facilitate the participation of user community.{color}

{color:#000000}&nbsp;{color}

{color:#0000ff}EURALO comments->{color} {color:#0000ff}Of prime importance in this section, is the issue of accountability and transparency, including public participation. Whilst this section is well furnished with key focus points, a vacuum exists through the lack of mention of the eventual role of At Large in public participation and accountability. This has not been raised either in the ATRT Report.{color}

{color:#0000ff}At Large would welcome working with ICANN to define this together in time for it to be included in future Strategic Plans.{color}

{color:#0000ff}Empowerment of local communities is essential for capacity building. AtLarge, with its structure of Regional At Large Organisations (RALOs) and local ALSes plays a key role in this regional empowerment and this appears to have not been pinpointed in the current plan. Indeed, there is no mention of "outreach", nor "inreach" of communities; no plan on{color}
{color:#0000ff}how to reach those communities.{color}

{color:#0000ff}A first step to outreach is the fellowship programme as well as the provision of on-line workshops and material to educate community leaders and participants about ICANN. This is a key brick in the building of stable international relationships and an efficient bottom-up decision process.{color}

{color:#0000ff}We therefore re-iterate At Large's plan of reaching out to communities worldwide so as to have One ALS per country. Currently At Large has 130 ALSes worldwide in more than 80 countries around the world. This unique resource needs to grow to cover every country in the world. That said, this unique resource also needs to be sustained. We are working hard to define better or more suitable ways of public participation and one of the tools used to keep ALSes, the grassroots of the whole ICANN eco-system, empowered, is the regular staging of Localised General Assemblies (GAs), as well as At Large Summits.{color}

{color:#0000ff}General Assemblies are important for local capacity building. So far, they have been organised ad-hoc with little or no budget in conjunction with an ICANN meeting taking place in the region. Some RALOs have organised their GA with no budget whatsoever outside the realm of ICANN and physical participation has been low because volunteers already{color}
{color:#0000ff}offering their time for free cannot be asked to pay costs except when taken care of by other means.{color}

{color:#0000ff}The ICANN At Large Review specified the need for one local General Assembly per year per region and this should therefore be reflected in the ICANN Strategic plan as part of a healthy Internet eco-system.{color}

{color:#0000ff}The At Large Summit taking place in Mexico City in 2009 was widely acknowledged by all, to have been a key factor in the capacity building of At Large leading to the ability of the ALAC to produce quality output to the standard expected by the ICANN Board. Whilst it was a textbook demonstration of ALS empowerment, it also demonstrated how communities{color}
{color:#0000ff}worldwide can focus their attention on key challenging subjects and find solutions together by consensus. This synergy needs to be repeated as part of At Large in-reach. Its purpose goes further than a merely social issue of having ALSes meet with each other and with ALAC leadership. Rather, this formidable force of hundreds of "Starfish" can unleash{color}
{color:#0000ff}powerful strategic benefits if its key subject focus were aligned with ICANN's Strategic planning. We therefore recommend that an At Large Summit become institutionalised as part of ICANN's natural processes ideally every 3 years, with an interval no larger than 4 years to keepgrass-roots interest high. The subjects on which the ALSes would work on would be a mix of ICANN-defined strategic subjects as well as grass-roots-defined issues, whether local or international.{color}

{color:#0000ff}It is anticipated that the results from such regular Summits would more than adequately support the "One World. Internet" vision, competently build stakeholder diversity, considerably improve accountability and transparency, expand international engagement and build trust in ICANN's stewardship by thinking Locally whilst acting Globally.{color}

{color:#000000}&nbsp;{color}

{color:#008000}LACRALO comments->&nbsp;{color}

{color:#008000}We believe there is general consensus among the  representatives of the RALOs for the need for annual GA for each RALO.  There is widespread evidence that a few days of F2F interaction gets  matters completed in a significantly shorter time frame than via online  communication.{color}\\

{color:#008000}We must assess the cost vs benefits for members  of the community, ICANN Staff and other stakeholders and explore  financing to hold an Annual GA per Region. If the GA coincides with an  ICANN meeting funding can be shared. In the last fiscal year, ICANN  modified its interpretation for “support to the RALOs”. During the  signature of MOUs between ICANN and the RALOs, the was no doubt about  the commitment of support (or at least an impression of such was made)  for the RALOs including financial assistance to ensure a GA (apart from  translations and interpretations).{color}\\

{color:#008000}In the same vein of AFRALO, we agree there is a  need for greater ICANN initiatives to encourage workshop participation  in the context of popular participation, governance and the{color}
 {color:#008000}Internet. ALAC is best suited to spearhead this.{color}\\

{color:#008000}Further, we need a regional approach and an  inreach/outreach program for the propagation of knowledge in the  Internet community and beyond.{color}

{color:#000000}&nbsp;{color}

{color:#ffcc00}NARALO comments -{color}{color:#ffcc00}>&nbsp;{color} {color:#ffcc00}The second strategic objective contains a gratifying reference to    ALAC, though the language reads "representing" rather than "elected by"    when referring to a seat on the ICANN Board.{color}

*Improve communications*

{color:#ffcc00}NARALO input=> The third strategic objective seems under developed  relative to   the other three, and adding a technical and policy  journal, similar to   the work Ole Jacobson has been doing, initially  for Dan Lynch's InterOp,   and subsequently for cisco, in his Internet  Protocol Journal, would be   more useful than more web ephemera.{color}

{color:#008000}LACRALO input=> LACRALO is pleased to see  the inclusion of “enhanced translation strategy” listed under staff  work. The translation of key policy documents, briefing materials,  presentations and transcripts; is critical to stakeholder diversity,  increased multi-stakeholder participation and wider international  engagement as listed in the draft Strategic Plan.{color}{color:#008000}No  doubt there is general consensus regarding the benefits of increased  document translations for the community to participate more effectively.{color}\\

{color:#008000}We acknowledge the hard work done by the new  translators group led by Christina Rodriguez (ICANN staff). Due to  technical and specific vocabulary used in our meetings it is of utmost  importance to maintain a stable team of translators. In the past we have  had to postpone teleconferences because it was impossible to understand  the translator.{color}\\ \\

{color:#008000}We must continue investing efforts in this regard to further enhance the worldwide end-user community input into ICANN.{color}\\ \\

{color:#008000}We agree with AFRALO that funding should be  increased for the translation of documents and simultaneous  interpretation in all meetings, including the fellowship program.{color}
 {color:#008000}Further, the number of Languages should be  increased, not only to improve Brazilian Portuguese native speakers in  the region but also to other languages such as Chinese,{color}
 {color:#008000}Russian, Arabic, etc.{color}




*Ongoing accountability and transparency.*

{color:#ffcc00}NARALO comments \->{color} {color:#ffcc00}The fourth strategic objective references fact-based policy development and decision making.{color}\\

{color:#ffcc00}Data as a necessary predicate condition to  "ensure the stable and    secure  operation of the Internet's unique  identifier systems", is    absent. This  is very unfortunate as in  practical terms, for each year    of the past  decade, persons with  nothing more than beliefs, which may    as well be  religious beliefs,  have dominated ICANN's policy making.{color}\\

{color:#ffcc00}The available data is not good. We are running  out of addresses, and     therefore must make a partially planned  transition without widespread     testbed experience of the new  infrastructure. The routing system too  is    at the limits of its  scalability. There are pervasive peer-to-peer     overlay networks which  are incongruent with economic models, and{color}
 {color:#ffcc00}therefore the source of fundamental legal  struggles over ownership and     control. The security and stability of  the naming, addressing and     routing infrastructure is problematic,  independent of anything ICANN is     on record contemplating as its plan  of record.{color}\\

{color:#ffcc00}Absent   operational data concerning unique  endpoint identifiers, unique     routing identifiers, and protocols,  stable and secure operations are     indistinguishable from instable and  insecure operations.{color}\\

{color:#ffcc00}The   DNS remains a private resource, where  access to profoundly  important    operational data necessary for basic  research on the range of     meaningful policy alternatives is at the  whim of commercial entities     acting under private law.{color}



{color:#000000}{*}On&nbsp;*{color}{color:#000000}{*}Trust in ICANN’s stewardship{*}{color}

{color:#ff6600}AFRALO highly appreciate the commitment to provide Internet governance education to an expanding group of international participants and to promote programs that enhance global participation. The AFRALO ALSes really need this kind of education to reach an effective participation in the ICANN policy development process.{color}

{color:#ff6600}The ICANN participation in the Internet Governance events such as IGF and WSIS forum is of high importance. AFRALO thinks that this participation shouldn’t be limited to nice formal speeches, or an ICANN parallel event, but needs to be more effective by organizing substantial workshops addressing actual subjects and involving the large population of the forum. This kind of participation will give ICANN more visibility and better credibility. The impact of the so-called substantial workshops will be greater if they are organized by the ICANN constituencies rather than the ICANN staff and/or Board.{color}


{color:#ff0000}APRALO comments->{color} {color:#ff0000}APRALO believes that ICANN should enhance its participation in pertinent  global fora, such as IGF and WSIS, while coordinating with its  community more closely and effectively in this regard.{color}



{color:#0000ff}EURALO comments->{color}


{color:#008000}LACRALO comments->{color}



h3. Conclusion

{color:#008000}LACRALO input=>{color} {color:#008000}Only through valuing the knowledge and perspective of end-users towards Internet rights and policies can ICANN reap future benefits for the proper use of ICTs in the specified public policy consideration makers.{color}