FINAL VERSION SUBMITTED (IF RATIFIED)
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FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC
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DRAFT SUBMITTED FOR DISCUSSION
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Final version 08 August 2019:
Draft submitted by Bastiaan Goslings on 23 July 2019:
Summary
The proposed evolution of the governance of the Root Server System in RSSAC037 is arguably one of the most significant, if not the most significant, processes in the history of ICANN.
The RSSAC and those who contributed to RSSAC037 are to be congratulated as is the ICANN Board for its response currently under discussion.
The ALAC strongly supports the overall proposal and appreciates the opportunity to comment on it.
The ALAC offers two specific comments:
- Section 4 of RSSAC037 discusses who the stakeholders of the RSS are. Absent from this list is the explicit mention of USERS (both individual as represented by At-Large and the rest of the users who rely on the RSS). Without those users, there would be no need for the RSS, as is emphasised a couple of times in RSSAC037. The ultimate ICANN model must encompass this and users should be explicitly represented on the the Root Server System Governance Board (RGB).
- The financial aspects of this proposal will be key to its success. At a time when ICANN’s budgets are being subjected to significant constraint, the Concept Model will without doubt have a high and ongoing cost. It is unclear where the Board currently visualizes these funds will come from. Once cost estimates are established, there should be a study of possible sustainable funding options. As important as the RSS is, the new funding must not come at great cost to other Community and non-DNS industry based activity support by ICANN org. From that perspective it comes as somewhat as a surprise that ICANN.org is not mentioned as a stakeholder in Chapter 4 while
RRSAC037, 12 June 2018
Although it might seem obvious, the ALAC first of all thinks it is important to state, as RSSAC037 notes numerous times, that the DNS Root Server System (RSS) makes the DNS root zone available to all DNS users on the Internet. The RSS must therefore be a stable, reliable, and resilient platform for the DNS service to all these users.
Since its inception the RSS has lived up to that expectation, and according to RSSAC037 the principles that have enabled this success of the DNS root service should remain core principles going forward. The ALAC agrees with this.
Root Server Operators (RSOs) have always operated completely independently, under their own good will and funding, and without any direct oversight by the stakeholders of the DNS Root service. A service which has been provided solely based on historical trust and integrity.
The ALAC thinks RSSAC037 rightly establishes the fact that changes to the RSS governance model are required as developments over the years have led to:
‘stronger needs for accountability, transparency, credible oversight, and continued scalability of the service to meet these demands. Stakeholders of the service must have accountability for its operation and assurance of its reliability and continuity.’
To achieve this, the RSS, according to RRSAC37, needs to evolve so it remains a reliable, resilient, and sustainable service in the face of increasing traffic and cyberattacks. Important parts of that evolution need to ensure that the operators of the RSS are accountable to their stakeholders, that robust processes exist to designate or remove operators, and that the operators have resources sufficient for its operation.
Delivery of the DNS root service indeed has essentially become a mandate for the RSOs, mostly unfunded by the non-RSO stakeholders of the service. The support and budget for providing the DNS root service comes from the RSOs’ parent organizations.
The stakeholders of the RSS are the people, groups, and organizations that have an interest or concern in the proper operation of the RSS. The primary stakeholders of the RSS are, according to RSSAC037:
- Internet Architecture Board (IAB) / Internet Engineering Task Force (IETF).
- ICANN community in the form of several of its constituencies.
- Set of current Root Server Operators (RSOs).
Reading chapter 4 it seems that ICANN.org is not considered a (primary) stakeholder with regard to the RSS. Which the ALAC finds strange.The RSOs’ parent organizations are regarded as stakeholders.
During the past four decades, operational costs have increased with no commensurate funding for the operators from the service stakeholder beneficiaries. RSSAC037 concludes that those entities that the RSS enables, need to take responsibility in funding the service that they depend upon.
The ALAC thinks this argumentation makes sense, and the option is mentioned for operators that are financially self-sufficient to choose to opt-out of general funding. However for the ALAC it is unclear to what extent current costs are (too) high for RSO’s, and what exactly the costs are for the respective RSOs to deliver and manage the DNS Root service. The ALAC appreciates that the RSSAC considers the proposed Model to be a starting point that requires ‘further deliberation, thoughtful analysis, and input from a broader set of experts from the ICANN community and beyond’, but more insight in the actual figures would help.
From RSSAC037 it is furthermore unclear who exactly should be responsible for providing the funding. A ball park amount is not referred to, ‘fully loaded FTEs’ are suggested to be used ‘as the main cost indicator’. 12 of those FTE’s are mentioned, as well as one year of operating fund on top of that for the start-up phase of the Model.
‘An RSS fund should be created by sourcing funds from numerous entities, including the stakeholders and the ICANN community.’ Numerous is rather vague, and looking at the list of primary stakeholders the only one that could probably afford the funding is the group of TLD operators. Where is ICANN.org in this picture? Again, it is not mentioned among (primary) stakeholders with regard to the RSS in RSSAC037. And that is ignoring the situation that ICANN.org operates as a RSO itself, which raises the question whether there is a potential source for a conflict of interest here.
A New Cooperation and Governance Model for the Root Server System, 23 April 2019
This concept paper, based on RSSAC037 and prepared by the ICANN organization (ICANN org), proposes to establish three new groups: The Root Server System Governance Board (RGB), the Root Server System Standing Committee (RSC), and the Root Server Operator Review Panel (RRP). These are in line with the functions that were envisaged in RSSAC037.
ICANN a.o. states that ‘In addition to these groups, ICANN org could manage Financial and Secretariat Functions.’ Furthermore from 3.4.2 (‘The Administrative Track – Planning for Implementation’) it seems apparent that ICANN.org will actually fund the implementation of the new Model. Where these funds will come from, from within the ICANN budget, remains unclear however. The process to estimate the costs is described in detail, but there is no referral to actual (estimated) numbers. Based on 5.5.3 of RSSAC037 (btw the ICANN.org concept paper refers to 5.3.3 in 3.4.2 but that presumably is a typo) the costs will be significant. Without further clarity the ALAC is concerned that this might come at a cost to other Community and non-DNS industry based activity support by ICANN org.
Draft submitted by Alan Greenberg on 21 July 2019:
This evolution of the governance of the Root Server System is arguably one of the most significant, if not the most significant, processes in the history of ICANN.
The RSSAC and those who contributed to RSSAC037 are to be congratulated as is the ICANN Board for its response currently under discussion.
The ALAC strongly supports the overall proposal and appreciates the opportunity to comment on it.
The ALAC offers two specific comments:
- Section 4 of RSSAC037 discusses who the stakeholders of the RSS are. Absent from this list is the explicit mention of USERS (both individual as represented by At-Large and the rest of the users who rely on the RSS). Without those users, there would be no need for the RSS. The ultimate ICANN model must encompass this and users should be explicitly represented on the RGB (Root Server System Governance Board).
- The financial aspects of this proposal will be key to its success. At a time when ICANN’s budgets are being subjected to significant constraint, the Concept Model will without doubt have a high and ongoing cost. It is unclear where the Board currently visualizes these funds will come from. Once cost estimates are established, there should be a study of possible sustainable funding options. As important as the RSS is, the new funding must not come at great cost to other Community and non-DNS industry based activity support by ICANN org.
18 Comments
Olivier Crepin-Leblond
First and foremost, this process is probably one of the most significant processes of the history of ICANN, after the new gTLD process.
This is the plan for the creation of a brand new ecosystem of Root Servers, which includes details of the overall management of these servers both locally and globally, the policy development process, the daily running activities, personnel levels, quality of service, contracts as well as funding of this ecosystem.
Having read RSSAC0037, all I can say is that I am very impressed by the whole proposal. Of course, the implementation of all of these plans is going to be crucial to the success of this roll-out, but as end users, we can only applaud the plans which are likely to strengthen the security and stability of the Root Server System.
On cause for concern, though, is the Financing of the whole plan, also defined as the "Finance Function". Whilst the ALAC should applaud that care is being put into finding a way to finance Root Server Operators that are unable to follow-up with the increasing pressure of larger, more powerful servers, and whilst there is a whole section in the proposal that speaks about Financial reporting, the source of this financing is clearly defined as ICANN. There is even a discussion about ICANN org reviewing potential conflicts of interest concerns related to its role as a Root Server Operator (RSO) and "performing the Finance Function".
ICANN has decided to stop the year on year increase in spending, adding a RSO Finance Function, whereas ICANN would finance a Root Server Operator, should that Operator show that it needs support (there is an option for a RSO to opt-out from being financed by ICANN), the question is where will these funds from from? Will this result in an additional levy on Domain Names, or will this come from an already stretched ICANN budget which might then need to cut Community involvement and outreach budgets further?
I have heard similar concerns from people in the NCSG.
Evin Erdogdu
With reference to Olivier's comment above, link to RSSAC037:
https://www.icann.org/en/system/files/files/rssac-037-15jun18-en.pdf
Cheryl Langdon-Orr
Fouad Bajwa
I also agree with your analysis Olivier and do have specific observations that may be prudent to explore when creating new governance structures and modifications within existing established organisational structures. Within the larger ICANN governance model, a new circle of governance has been suggested for the RSO. This structure creates three new sub-governance circles primarily a Root Server System Governance Board (RGB), the Root Server System Standing Committee (RSC), and the Root Server Operator Review Panel (RRP). That is three new structures to govern, provide governance, to staff, to organise, to be made transparent, accountable and operate in the public interest. I agree that there is a broader scope of responsibilities being self-assigned but closely looking at the clarifications being given, this still is within ICANN's remit and the Internet Community has somewhat established an evolutionary multistakeholder mechanism that can already support any new governance system however it is not recommended to create something completely new. Many of the operational explanations given in the RSSAC0037 can be well managed without such new governance structures. According to section 2.1. The statement "ensuring that the resulting membership contains the breadth and balance of skills needed, including technical, policy and governance expertise." can never be achieved in its totality however a great deal of these breadth and balance of these skills are already available across the ICANN community.
An independent community group within ICANN can also manage all monitoring, measuring and evaluation of the Root system. This can be a cross-community elected membership that already has recognition and good standing amongst the broad community. The RRP also feels as a conflicting suggestion within this circular governance structure. One group can perform all three functions without the need for creating so many independent functions of each other. The financial requirement is quite a concern as it calls for shaking the pockets of already constrained ICANN financial policy. I personally would not support create a new expense head like this especially when something has been long managed without such a need. Suddenly squeezing ICANN through a new super structure is not useful, recommended or even suggested.
Holly Raiche
I agree with both sentiments being expressed:
the new, more transparent and accountable structure is to be applauded
the impact on ICANN's budget (and ALAC's budget) need to be considered. That said, the importance of this major reform must be funded.
Jahangir Hossain
I am very impressed by the whole proposal after reading the RSSAC0037. This is true that a new governance structure is required in future by considering the scale operations, emergencies, research and robust service development as rapidly growing billions of hosts/ users.
Definitely the impact on ICANN's budget and ALAC's budget need to be considered in future.
Abdulkarim Ayopo Oloyede
I agree with the earlier analysis, and I believe this document is broad enough, especially as it also guarantees the independence of each of the root server operators.
I think the internet has grown significantly and it would continue to grow therefore the need for the governance of the root server to continue to evolve. There is also a need to have a sustainable funding mechanism for the root servers systems. The concern to end user with the financing function (FF) would be how to guarantee the continued independence of the root servers from the influence of those funding the RSS. The process of receiving external funding must be transparent, more especially when government(s) funding is involved.
The evaluation and selection of new RSO, removal of RSO should also be transparent such that, the criteria that would be used in evaluating the applications and removing RSO should be well defined to avoid ambiguity. Adequate, Impact analysis on end users should also be carried out in case of removal or resignation of an RSO.
The mechanism for immediate suspension of an RSO that goes rogue should also be more specific in terms of the timeline for recommendation to the board and timeline for the board to take a quick decision to reduce the impact on users.
Alan Greenberg
I believe that our statement needs three components:
Alan
'* I am told that it WAS discussed but this position did not win sufficient support.
Alan Greenberg
From Cheryl's comment: " The raising of concern that the necessary financial support of RSOs as needs be, should not come at great cost to other Community and non DNS industry based activity support by ICANN.org is also important to make in a short response as well... "
I agree.
Alan Greenberg
Proposed Draft Comment
This evolution of the governance of the Root Server System is arguably one of the most significant, if not the most significant, processes in the history of ICANN.
The RSSAC and those who contributed to RSSAC037 are to be congratulated as is the ICANN Board for its response currently under discussion.
The ALAC strongly supports the overall proposal and appreciates the opportunity to comment on it.
The ALAC offers two specific comments:
Evin Erdogdu
Thank you Alan, this has been posted to the "Draft Submitted for Discussion" section of the workspace, above.
Carlton Samuels
I'm particularly drawn to both OCL's and Alan's statements reflecting on the stakeholders in the goivernance structure and the fit-for-purpose funding model. First, I endorse the explicit mention of users and their representatives for a role in the governance structure on tap. Second, there is a real concern that funding requirements could exclude organisations that could host a root server in the public interest.
I can tell you that when I had the responsibility - and budget authority! - for university ICT support systems, Steve Huter of the NSRC at Oregon State Univiersity suggested that the UWI host a root server in service of Caribbean internet users. The cost implications for the university were not helpful to getting the proposal ratified by the University Senate so it died. I should think there are others elsewhere that were seized by this challenge. Would that there is a sustainable solution on offer to overcome this.
Bastiaan Goslings
I drafted a text based on my own interpretation and notes, including other's comments and copy/pasting Alan's proposal in the 'summary'. Hope this is useful. I think we all agree on the main points
Alan Greenberg
Overall, I think this is good.
I would cut out most of the part starting with "However for the ALAC....". It wanders all over the place and since it is based on unclear statements, it is equally unclear.
Replace it with a simple statement that the funding model being discussed is overly vague and since funding will be a critical part of any new model, we need far more clarity,
I would not presume that ICANN is the only source. RSSAC037 makes it celar that those who benefit should have some responsibility.
Two specific points:
Alan
Bastiaan Goslings
Thanks, Alan - so ‘overall’ the text is ‘good’ and then you burn it. I actually thought that was quite funny ;-)
Seriously. I tried to make a link between (gaps in) RSSAC037, especially with regard to funding of the new Model (= lack of rationale/numbers when it comes to current situation and how in the new Model costs are then to be covered and by whom) and the concept paper that came almost a year later from ICANN.org itself. Apparently I did not succeed and that is fine. Personally I do like to add context and quote documents I am referring to, also for people who have not read the proposal and underlying documents. If that results in text being redundant that is a matter of taste but I am totally ok with it if the groups decides it should not be there.
(I for example would never say ‘This evolution of the governance of the Root Server System is arguably one of the most significant, if not the most significant, processes in the history of ICANN’, definitely not without explaining what it means. However that too is probably a personal preference and I left it in there)
You say: ’I would not presume that ICANN is the only source. RSSAC037 makes it celar that those who benefit should have some responsibility.’
Exactly. I know what RSSAC037 says and then what the ICANN.org concept paper proposes. So if my presumption is indeed incorrect that makes matters even worse.
Sorry for the ‘ICANN a.o. states’ btw, I should have cleaned it up - I meant to write ‘ICANN among other things states’
Abdulkarim Ayopo Oloyede
Hi,
I agree with the entire text execpt that I don't understand what ICANN a.o means. However, I think some of the issues outside of the financial issues were not well covered.
Thanks
Bastiaan Goslings
Thanks, Abdulkarim
Holly Raiche
Now I am a bit confused - and we are supposed to be voting. I did appreciate Bastiaan's text, giving some context to this issue. So are we saving it or not.
I also agree that, over all, we need to make the three points that everyone supports