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Dr. Olivier Crépin-Leblond, Chair of the At-Large Advisory Committee (ALAC) originally composed this statement based on archived documents of the ALAC as well as wide input from the five Regional At-Large Organizations (RALOs).

A wiki workspace on the NTIA NOI, including a time-line for comments, was announced on 17 March 2011 on an At-Large Group Skype Chat during the 40th ICANN Meeting held in San Francisco. Following a call for comments on the ALAC-Announce mailing list which was posted on 18 March 2011, Dr. Crépin-Leblond drafted a first version of the ALAC Statement on the NTIA NOI which was discussed during an ALAC Executive Committee call on 24 March. Following this call and the addition of significant community input a second version was created.

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The original version of this document is the English text available at www.atlarge.icann.org/correspondence. Where a difference of interpretation exists or is perceived to exist between a non‐English edition of this document and the original text, the original shall prevail.

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Statement of the ALAC on the US National Telecommunications and Information Administration Notice of Inquiry

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That said, we fully support the Final Report of the Delegation, Re-delegation and Retirement Working Group of the ccNSO (http://ccnso.icann.org/workinggroups/final-report-drd-wg-17feb11-en.pdf) which recommends: “...as a first step, the ccNSO Council undertakes the development of a "Framework of Interpretation" for the delegation and re-delegation of ccTLDs. This framework should provide a clear guide to IANA and the ICANN Board on interpretations of the current policies, guidelines and procedures relating to the delegation and re- delegation of ccTLDs.

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Furthermore, while ICANN is yet to fully realize its potential as a bottom-up multi-stakeholder policy development organization, we envisage a time when its role in the process for root zone management as defined in (http://www.ntia.doc.gov/DNS/CurrentProcessFlow.pdf) might be expanded to encompass the role of the Administrator, in addition to its current role as the IANA Functions Operator, provided that ICANN has established a process for the role of the Administrator that is accountable, transparent and serves the global public interest.

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We therefore suggest an out of contract continuous self-appraisal process with mid-point review of improvements using the robust multi-stakeholder review process used in ICANN Reviews. This multi- stakeholder model can be utilized, to provide a framework to analyze the issues requiring improvement and create an environment for making consistent and predictable decision, as illustrated in the Final Report of the Delegation, Re-delegation and Retirement Working Group of the ccNSO. (http://ccnso.icann.org/workinggroups/final-report-drd-wg-17feb11-en.pdf)

This improvement process is directly related to our answer in Question 3, whereby the transparency of the IANA Functions Operator in the processing of the delegation and re-delegation of ccTLDs should be improved as the decisions taken by IANA directly affect the local Internet community stakeholders governed by the ccTLD.

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