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As for the substance, the ALAC is glad that the draft FY12 Operational Plan and Budget has been presented with sufficient explanation and details in order to allow for deep discussion and comments.   

 NeverthelessNevertheless, the ALAC wants to make the following remarks:

1)  In the draft FY12 Budget and Strategic Plan, paragraph 4.7 regarding community support

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describes, comprehensively, the process of dealing with the additional service requests from ICANN constituencies, but it does not

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explain how these requests were treated and decided upon by the staff.

As far as At-Large is concerned, most of the limited resources allocated do not cover the projects applied for.  At-Large applied for these projects, not for money.  Hence, by replacing the funding pf a RALO General Assembly (GA) with six additional travel support slots will not, for example, allow the GA to be held.

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Now, with the FY12 Budget in draft form, the ALAC is still asking for the funding of these same projects.  In addition, for those projects that can not be funded, we are asking for clear explanations of why they have been rejected or postponed.  Finally, we request a formal statement of when the non-funded projects will, in fact, be funded.     

2)  In paragraph 4.8 regarding policy development support, there is a provision allocating resources for the implementation of improvements requested by the ALAC, consisting, inter alias, of support during 2010-13 for one General Assembly (GA) for each of the five Regional At-Large Organizations (RALOs), held in conjunction with either an ICANN or key regional Internet stakeholder meeting in order to set priorities and develop strategies for improving participation, including capacity-building programs.

Since no support for GA was budgeted in the first year (FY11) of this period, At-Large had expected resources allocated for at least two GAs in FY12, but unfortunately none has, in fact, been funded in the current draft budget.

3)  The At-large Community was the only ICANN entity to specifically request funding to support the strategic objective of participation in Internet governance dialogues -- specifically in the Internet Governance Forum (IGF).

A workshop organized at the IGF by an ICANN community constituencies would have a much larger effect in showcasing the ICANN multi-stakeholder bottom-up process than would any official speech. The success of the AFRALO workshop held in Vilnius last year (without any ICANN support) demonstrates this clearly. The ALAC thinks that such request deserves to be funded.

4)  In the new gTLD program budget, we did not see any provision for the support of the applicants needing assistance in applying for and/or operating a new gTLD, as per ICANN Board resolution 20 made in Nairobi.  The ALAC thinks that a reasonable percentage of the application fees recovered by ICANN should be allocated to this support.

5)  Outreach plans, using media (e.g., podcasts to countries/jurisdictions without ALSes) were rejected, with the reasoning that any action should be deferred until the Public Participation Committee (PPC) has the opportunity to develop an overall outreach plan for all constituency and stakeholder groups. We strongly suggest that At-Large be included in the development of this overall outreach plan to ensure its success.

6)  The ICANN Developing Countries Summit is planned to take place in Dakar, during the ICANN 42^nd International Meeting. While the ALAC welcomes such an initiative to promote the developing countries' participation in the ICANN process, and especially in its policy development, it notices that no financial provision has been dedicated to this very important event.  The ALAC believes that resources should be allocated to such an event, if this allocation has not already been made.  And if the allocation has been made, we would like to know which item within the draft budget includes it.  

7)  While the ALAC recognizes the ICANN efforts in the translation field to increase translated documents and maintain a multilingual ICANN blog, it notices with concern that no improvement in the interpretation field is expected.  The quality of the interpretation is sometimes unacceptable, and all the working groups are working in English only, which prevents the non-English speakers from participating.  The impact of such a situation is that these non-English speakers cannot fully participate in the policy development process. The ALAC considers this issue a priority for an international organization that boasts of being inclusive and multi-stakeholder with a bottom-up decision making system.

8)  The registry fees for the 18 existing gTLDs do not follow any rule and show an arbitrary way of charging registries.  Some do not pay the fixed fees, while others do not pay the per-transaction fees.  In addition, the value of the fixed and the per-transaction fees change from one registry to the next. For example, the dot com does not pay the per-transaction fees, while the dot cat (community TLD) pays the per-transaction fees at one of the highest rates ($1 per transaction), as well as the fixed fees. The ALAC does think that the community not-for-profit TLDs should be charged at a minimum rate, while the lucrative TLDs should be charged normally, according to well-defined rules. 

9)  Regarding the implementation of impact reporting, we have noted and appreciated the Impact Analysis pertaining to Deployment of DNSSEC in the Root Zone and the document summarizing the Impact of Root Zone Scaling.  As ICANN moves forward, we would recommend that ICANN consider additional types of impact reporting, such as the impact of ICANN’s policies on TLD growth in developing countries.

10  Finally, we appreciate the call to fine-tune the determination of the most appropriate level for the Reserve Fund, and we will tender comments on this topic at the earliest opportunity.

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