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INDIAN PERSPECTIVE ON THE IANA STEWARDSHIP TRANSITION on the Indian Perspective on... · The new...
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Conducted by CCAOI
A STUDY ON THE
INDIAN PERSPECTIVE
ON THE
IANA STEWARDSHIP TRANSITION
Supported by:
Indian Perspective on IANA Stewardship Transition
CCAOI Confidential Report, 21st March 2015 Page 3
ACKNOWLEDGEMENTS
This report was made possible through the help and generous support from many
stakeholders of internet governance India.
We wish to especially acknowledge the contributions and assistance of Dr. Govind, CEO-
National Internet Exchange of India, ex-Senior Director Department of Electronics and
Information Technology; Mr. K.B. Narayanan, Advisor, National Internet Exchange of
India, Mr. Rajesh Chharia, President Internet Service Providers Association of India, the
entire National Internet Exchange of India team, for providing support and encouragement,
without which this study would have been impossible.
We are grateful for the valuable inputs, cooperation, important perspectives and support
provided,
Mr. Sunil Abraham, Executive Director, Centre for Internet and Society, India; Mr. Rishabh Bailey Vice President ,Free Software Movement of India; Ms. Pallavi Bedi and Mr. Chaitanya Ramachandran, Associate, Amarchand &
Mangaldas & Suresh A.Shroff & Co.; Mr.Thanglura.Darlong, Joint Secretary, Counter Terrorism Policy Planning &
Numbers; Dr. Rekha Jain, Executive Chair, IIMA-IDEA Telecom Centre of Excellence;
Dr. Ajay Kumar, Joint Secretary, Department of Electronics and Information Technology;
Mr. Sivasubramanian Muthusamy, President, ISOC Chennai Chapter; Mr. Ram Narain, Deputy Director General ,Security & Access Services-II,
Department of Telecommunication; Mr. Parminder Singh, Executive Director, IT for Change; Mr. Arun Mohan Sukumar, Senior Fellow, Centre for Communication Governance; Mr. Vikram Tiwathia, Associate Director General, Cellular Operators Association of
India;
Research, Ministry of External Affairs; Mr. Samiran Gupta, Head of India, Internet Corporation for Assigned Names and
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CONTENTS
INTRODUCTION ...................................................................................5
METHODOLOGY ................................................................................13
STRENGTH AND WEAKNESS IN THE CURRENT EXECUTION OF
IANA FUNCTIONS ...............................................................................14
AN OVERVIEW OF PROPOSALS FOR THE IANA TRANSITION .....18
SUMMARY OF FEEDBACK FROM INDIAN STAKEHOLDERS ........29
DISCUSSIONS AND RECOMMENDATIONS ......................................47
ANNEXURE .........................................................................................53
ABBREVIATIONS ................................................................................53
KEY INTERNET GOVERNANCE ORGANIZATIONS .........................54
MEMBERS OF IANA STEWARDSHIP TRANSITION COORDINATION
GROUP (ICG) .......................................................................................66
QUESTIONNAIRE ...............................................................................68
ABOUT CCAOI ....................................................................................73
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INTRODUCTION
Each device connected over the internet is assigned a unique numeric address called Internet Protocol number (IP) by which it can be identified. Since IP numbers (like ―74.125.19.147‖) are difficult to remember, for easy recall, they are assigned a corresponding distinct domain name (like www.google.com). Domain names are alphanumeric strings, divided into sections and organized from right to left with each level separated by dots. In a domain name (like www.google.com), the Top level domain name is the right most portion of the domain name (i.e.,".com") and is the highest level of the domain name, the specific description to its left (i.e., "google") is called the Second-Level Domain, while the machine name ( i.e., ―www‖) is at the extreme left. DNS has three types of top level domain names, namely, Generic Top Level Domain Name (gTLD), Country code Top Level Domain Name (ccTLD) and Sponsored Top Level Domain Name (sTLD). Generic Top Level Domain Name (gTLD) normally has three or more characters such as .com, .net, .org, etc. and are managed by a Registry (like Verisign in the case of .com). The two letter domain names representing countries are called Country code Top Level Domain Name (ccTLD). For example, the .in is the ccTLD for India. There are some specialized gTLDs representing a specific community such as .aero, .cat, .coop, .jobs, .mobi, are called Sponsored Top Level Domain Name (sTLD). The new gTLD policy allows an entity to register a TLD with a name of their choice such as ―.tata‖ or ‖.airtel‖. Also, with more and more non English users being added, having non-English domain names such as Chinese, Arabic, Devnagri (Indian) scripts is possible under Internationalized Domain names (IDNs). One such IDN available in India is ―. (.Bharat)‖. Domain Name System
In order to ensure that each networked device gets the requested information correctly, the records of all IP addresses and their corresponding domain names are managed and maintained by a directory called the Domain name system (DNS). On receiving a domain name request (like www.google.com), the DNS translates this information into the right IP address (like ―74.125.19.147‖), so that the requested information (the Google webpage) can be correctly provided to the requestor. The DNS is fundamentally a shared name space having root servers (name servers) that implement the name space; and resolvers (or caching servers) in the middle, connected to end systems that send queries about the name space to the name servers. At the top of the DNS tree sits the root zone, which is implemented in the root servers (or name servers) for users. The DNS is hierarchical in nature, allowing parts of the name space to be distributed and delegated to other authoritative name servers in the Internet. It also has caching servers (or DNS resolvers) that cache responses from authoritative servers, on receiving queries from their client end systems. The hierarchal nature and use of resolvers have helped in the growth and scalability of internet.
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The DNS name space database has been divided into zones and each zone is served by one or more name servers which are synchronized to contain identical sets of data. The zones are hierarchically organized like an inverted ―tree‖, zones containing DNS information belonging to the corresponding name domains in the tree. The root zone constitutes the top of the inverted tree (level 0) and its name is an empty string (not ―root‖) denoted with a single ―.‖ (period or ―dot‖). The DNS data in a zone are usually stored in the zone file and servers through the process called zone transfer synchronize the contents of the master server (the server at which changes to the zone in question are entered) with slave servers.
Fig: Domain Name System Hierarchy1
Example of how the DNS works
When a query for a website like ―www.google.com‖ is sent by a networked device, it is sent to one of the caching servers which keeps a list of root servers and their addresses. In case the cache is newly installed and has no prior information, it will ask the root server. The root server in turn will answer with a referral containing the list of all servers for ‗com‘. The caching server will then send the request to one of the authoritative servers and get the information on 'google.com'. The next time any one sends a query for the address to www.google.com, the caching server can itself answer the request without consulting any server. In case the caching server ____________________________________
1 http://en.wikipedia.org/wiki/Domain_Name_System#mediaviewer/File:Domain_name_space.svg
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receives a query for ‗anything.google.com‘, it will send the query directly to the ‗google.com‘ server and send any question for another name ending in ‗.com‘ directly to a server‘s authoritative for ‗com‘. In case the query is different example for .org and it had previously not received any such query, it will ask the root server. In this way the cache will contain lists of authoritative servers for all popular domains, especially for all popular TLDs. This design ensures that only a tiny fraction of all queries will have to be processed by the root servers or by authoritative servers for TLDs.
Figure: How DNS works2
Root Servers
The DNS name servers (also called root name servers or root servers) carry and serve data from the root zone. There are 13 publicly accessible root servers, denoted by the letters A through M. Each server carries DNS hostnames in the form <letter>.root-servers.net (for example, a.root-servers.net). The root servers are updated by a distinct distribution master (also referred as the "hidden master") which is not visible in the DNS system and is operated by root zone administrator. To minimize the errors and attacks during updates, validation of digital signatures and error checking are in place between the distribution master and the respective slave systems.
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2 An Introduction to Internet Governance, By Jovan Kurbalija, http://www.diplomacy.edu/sites/default/files/An%20Introduction%20to%20IG_6th%20edition.pdf
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Out of the 13 root servers, 10 are located in the USA and one each in Sweden, the Netherlands, and Japan. The locations of the root servers were initially determined based on the network traffic flow and load analysis. However, with time, it was felt that the locations of the root servers were limited and it was important to have root servers distributed for providing a sufficient level of service to all users across the network. As a result, several satellite sites having copies of the root servers have been deployed by using a method called Anycast. Due to these deployments, the load balancing, and multiprocessing, through which a root server can comprise multiple processors; the number of computers at each root-server address has effectively increased. Root Zone File
The Root zone file is a public file, containing the list of all the TLDs - their names and corresponding set of resource records that build up the pointer structures leading the clients onwards and downwards in the DNS hierarchy. Thus a TLD will only be visible to public in the internet if it is listed in the root zone. The actual and current root zone file is used by all the root server operators. However, the root server operators do not have the power to make any change in the file, as the right to modify or update and then publish the contents in the root zone database rests with the root zone management authority. As the root zone is the first level of the DNS system, listing all the public TLD‘s, it is very important from a network and political standpoint. For smooth operations/working of internet and the DNS, it is critical that the information stored and distributed by the root zone file is accurate and correct; the root servers are secure, efficient and reliable. Even the smallest error such as entering incorrect domain name or IP address in the root zone file will result in incorrect information. Also, if the error is updated in all copies of the root zone file, access would effectively be denied to all domain names in that TLD. Root Zone Management Process
As the root domain and its corresponding zone is critical for the operation of DNS, the management of the root zone process is very important. Functions such as deciding what entries (new/revised) to be included in the root zone file, creating, updating and distributing the root zone file to all of the root name servers, selecting the locations and the operators of the root name servers; and establishing and continually and reliably operating the root name servers is very important.
The Internet Assigned Numbers Authority (IANA)
During the initial days of internet, for managing and distribution of IPs and top-level domains, the Internet Assigned Numbers Authority (IANA) was set up and was administered by the Information Sciences Institute (ISI) at the University of Southern California (USC) under a contract with the US Department of Defense. However, the task was performed by an individual, Jon Postel.
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However with time, the IANA activities have grown and, today, can be broadly classified
into three categories:
Management of Domain names including information contained in the DNS
root, the .int and .arpa domains, and an IDN practices resource
Coordinating Number resources by managing the global IP pool and AS numbers and providing them to Regional Internet Registries (RIRs). Autonomous system (AS) is a collection of connected Internet Protocol (IP) routing policies for one or more network operators that are controlled by a common administrator on behalf of a single administrative entity. AS are assigned a unique global number called Autonomous System Number (ASN) that are assigned in blocks to RIRs by IANA, who then assign them within their designated areas.
Managing internet Protocol codes in conjunction with standards bodies. Since 2008, the IANA is operated by ICANN under a contract from the U.S. Department of Commerce and a Memorandum of Understanding (MOU) with the Internet Engineering Task Force (IETF). The agreement has been extended twice. The existing contract would be expiring in September 2015.
Organisations and their roles
DNS Root Zone Management
There are various organisations involved in the DNS root zone management process. These include:
ICANN, a California incorporated not for profit body managing the IANA operations, under a contract from the U.S. Department of Commerce since 2008. Extended twice, the existing contract would be expiring in September 2015;
The National Telecommunications and Information Agency (NTIA) of the
U.S. Governments, Department of Commerce, responsible for reviewing and approving function that authorizes any change to the root zone;
Commercial entity VeriSign who is contracted by NTIA (Cooperative Agreement No. NCR 92-18742) to perform the role of root zone administrator;
And an informal group comprising of commercial, non commercial and governmental root server operators.
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Figure: Root Zone Management Players3
Out of the ten root servers in U.S., three are with the U.S. government (National Aeronautics and Space Administration (NASA), Department of Defense (DoD), and the U.S.Army), two are operated by universities (University of Maryland and University of Southern California), two by corporations (VeriSign, Inc. and Cogent Communications), and two are run by not-for-profits (Internet Systems Consortium, Inc. (ISC) and Internet Corporation for Assigned Names and Numbers (ICANN)). The root server in Sweden is operated by a not for profit corporation (Autonomica AB), the one in Netherlands by a co-operative body (The RIPE Network Coordination Centre—of European Internet Service Providers), and the one in Japan by academics (WIDE Project). Coordination of Global Number Resources
As a part of the IANA function, ICANN is responsible for allocating blocks of IPs, from the pool of unallocated IPs to the 5 Regional Internet Registries (RIRs) spread across the globe, in accordance with global Internet number policies. The RIR's in turn distribute IP numbers to the local Internet registries (LIRs) and national Internet registries (RIRs), who in turn distribute IP numbers to smaller ISPs, companies, and individuals further down the ladder... for example, if someone wants an IP address in India, they can purchase it from an Indian ISP (like Airtel), who in turn might purchase it from the National Internet registry of India (called IRINN), who in turn gets the same from RIR (called Asia Pacific Network Information Centre (APNIC)), who in turn gets it from ICANN. Since each RIR represents a geographical area, they have their own processes and interests, that is why single body called Number Resource Organization (NRO) has been set up for coordinating between them and ICANN. Each RIR appoints 2 members through their regional policy forums, and another member comes from each RIR's executive board and they constitute the ASO Address Council (ASO AC). The Address Supporting Organization (ASO) is one of three ICANN Supporting Organizations, whose main objective is to review and develop Internet Protocol recommendations, address policy, and advise the ICANN Board4. Under an agreement between ICANN and NRO called ―The ICANN Address Supporting Organization (ASO)
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3 Scaling the Root, https://www.icann.org/en/system/files/files/root-scaling-study-report-31aug09-en.pdf 4 https://aso.icann.org/
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MoU5‖, NRO is to liaise with ICANN about Internet number resources on behalf of the
RIRs6. Growth in internet users has led to a shortage of IP addresses, since the 32 bit IPv4 address space offered only around 4 billion unique address options. This led to the introduction of the 128 bit IPv6 version, allowing huge numbers of unique IP addresses. Today, both the versions of IPs, IPv4 and IPv6. are operational and need to be managed. Management of Protocols
To ensure that each requestor on the internet gets the correct information, all networked devices need to follow the same set of rules or protocol parameters and the commonly used protocol is Transmission Control Protocol/Internet Protocol (TCP/IP). The TCP/IP ensures that messages can pass between two hosts, back and forth over a period of time. Currently the Internet Engineering Task Force (IETF), under MoU with ICANN (MoU RFC2860), is responsible for setting TCP/IP standards and managing internet standards processes. The type of oversight, policy formulation and process of implementation and maintenance is important. The management group of IETF is called the Internet Engineering Steering Group (IESG).The Internet Architecture Board (IAB), a committee of IETF and also an advisory body in ISOC, is responsible for providing architectural oversight of IETF activities. It also provides Internet Standards Process oversight and appeal, and the appointment of the RFC Editor. The IAB is also responsible for the management of the IETF protocol parameter registries. The Internet Society (ISOC), a non-profit organization, is the home to IETF and IAB. The World Wide Web Consortium (W3C) is an international community working to develop Web standards.
Current Status National Telecommunications and Information Administration (NTIA), an agency of the US government, which supervises the IANA functions through a contract, plans to relinquish its oversight. It announced in March 20147, its intention of shifting key Internet domain name functions to the global multistakeholder community when the IANA contact expires in September 30, 2015. NTIA has mandated ICANN to coordinate a process for interested stakeholders to develop a transition proposal. It wants that the proposal must:
support and enhance the multistakeholder model
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5 https://aso.icann.org/about-the-aso/aso-memorandum-of-understanding/ 6 https://www.icann.org/resources/pages/governance/bylaws-en#VIII 7 NTIA Announces Intent to Transition Key Internet Domain Name Functions, March 14th, 2014, http://www.ntia.doc.gov/press-release/2014/ntia-announces-intent-transition-key-internet-domain-name-functions
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maintain the security, stability, and resiliency of the Internet DNS meet the needs and expectations of the global customers and partners of the IANA
services, and maintain the openness of the Internet.
Crucially, the NTIA has also made it clear that it ―will not accept a proposal that replaces the NTIA role with a government-led or an inter-governmental organization solution.‖ It is important to underline that The NTIA declaration8 called for a transition of NTIA stewardship over IANA functions and not for transition of IANA functions. As the effects of the domain name functions have a far reaching impact on communities both connected or unconnected to the internet, the transition process has gained immense interest of governments, business houses, academics, civil societies, etc. The discussion on the transition, addressing the concerns pertaining to the existing DNS process, has enlarged to the accountability of ICANN as well.
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8 https://www.netnod.se/iana-stewardship-transition
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METHODOLOGY
CCAOI staff conducted this study under the guidance of Dr. Mahesh Uppal a telecom and
internet consultant. Ms. Amrita Choudhury led the research effort from CCAOI.
The aim of this study is to identify the issues related to the NTIA stewardship transition from
the IANA operations, the different strains of thoughts, along with their convergence and
divergence, review the central issues from India perspective after extensive consultation with
stakeholders, highlighting their importance and make recommendations on what should be
the most appropriate position for India
The study was conducted over a period of three months. It involved:
Identifying and studying the relevant issues from secondary data.
In-depth study of key issues through study and critique of relevant secondary data.
Interviews with key players and experts based on fine-tuned questionnaires, and
interviews. The questionnaire, list of people sent the questionnaire or interview invite
are provided in the annexure.
Attending workshops and round tables of experts and stakeholders from civil
societies, government, academics, corporate, students, users, etc.
Validation and consolidation of results.
This study has limitations. It is time bound, and relies on secondary sources and often-
unstructured interviews. It must be distinguished from rigorous and exhaustive academic or
legal research.
The report quotes freely from existing documents. We have made every effort to attribute
sources as far as possible. We do not imply that the quotes refer to the official positions of
those quoted or their organizations. We accept responsibility for any errors in this report.
We propose, as a next step, to do an in-depth study on the subject of accountability of the
IANA operator and their impact on different stakeholder groups in India.
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STRENGTH AND WEAKNESS IN THE CURRENT
EXECUTION OF IANA FUNCTIONS
The execution of IANA functions has been frequently lauded for its professionalism and speed. Others have expressed their concerns on issues such as equity. This section highlights some of these views below: ICANN as an Organization
Many, e.g. ISOC9 considers the self regulatory model of internet and the role played by ICANN in coordinating certain aspects of the ―collaborative‖ internet model, a strength , Operationally, ICANN is known10 to be well positioned in managing the IANA function. The organization has also been delivering,11 basis its role as per its IANA contract. Lawrence Strickling12, Assistant Secretary for Communications and Information and Administrator of the National Telecommunications and Information Administration (NTIA) under the U.S. Department of Commerce (DOC), argued in 2011 that ICANN‘s achievements include introduction of 27 Internationalized country code top level domain names (IDN ccTLDs), the implementation of a review team process as stipulated in the Affirmation and the effort made by the ICANN Board and the Governmental Advisory Committee (GAC) to work together to increase the number of generic top level domain names (gTLDs). ICANN has frequently faced criticism for its policymaking role and for deriving excessive profits from its functions13. Senator Wyden14 raised ethical concerns about senior ICANN controversially moving to and from industry and conflicts of interest in the IANA function. Strickling shared concern15 over some of ICANN's decisions to remove the cross-ownership restriction and the Board‘s decision to reverse its commitment to conduct further economic studies regarding the impact of new gTLDs. Root server System
ISOC believes that the existing single root server system reduces the risk that some governments might misuse the DNS for censorship. This minimizes chances of fragmentation of the internet.16
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9 https://www.internetsociety.org/sites/default/files/pdf/ISOC_NTIA_response_060707.pdf 10 [discuss] The NTIA/ICANN transitioning Process, By Seun Ojedeji, 29th March 2014, [email protected] 11 [discuss] The NTIA/ICANN transitioning Process, By Seun Ojedeji, 29th March 2014, [email protected] 12 http://www.ntia.doc.gov/speechestestimony/2011/keynote-remarks-lawrence-e-strickling-assistant-secretary-commerce-communicat 13 Milton Mueller book on Nations and internet 14 http://wyden.senate.gov/newsroom/press/release/?id=2e414e69-1250-4ca3-ae6b-2b6091ed52cc 15 http://www.ntia.doc.gov/speechestestimony/2011/keynote-remarks-lawrence-e-strickling-assistant-secretary-commerce-communicat 16 https://www.internetsociety.org/sites/default/files/pdf/ISOC_NTIA_response_060707.pdf
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There is concern that the existing root server process provides the US government the power to make unilateral changes in the entire DNS. Louis Pouzin, believes that in the current single root server system there are chances of misuse of data by a single country vis a vis creating multiple roots.17 Root Server Model
The non-hierarchical distributed arrangements within the root name server system, and the diversity of software, hardware and operational procedures used by each of the servers, are key elements that contribute to a stable and secure root system. ISOC believes that this distributed and redundant root server model as operated by a dozen independent organizations provides maximum stability and security. They therefore see no benefit in centralizing management of the root name server operators.18 The current agreement between NTIA and ICANN obliges the latter to seek operational authority over the DNS root name server system. This is done through formal arrangements with root name server operators. ISOC19 is concerned, as they fear that it will eventually introduce risks in times to come. Oversight
There is almost a universal concern20 regarding the unilateral oversight of U.S. government on how ICANN operates administratively. Such a system is believed21 to restrict ICANN from fully serving the global ICANN community. Role of Governments
ISOC is concerned over the increasing role of governments in ICANN than what is necessary for the security and stability of internet.22. Others have argued that its role in functions e.g. gTLDS and ccTLDS cannot be carried out without significant role for governments. Names and Accountability of ICANN
Accountability of ICANN, Milton Mueller suggests, is a concern for most ccTLDs and gTLDs.23 He further adds that as gTLD‘s are under contractual license with ICANN, the latter has the authority to levy expensive and burdensome contractual obligations on registries and ICANN‘s powers need to be limited.24
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17http://www.thehindu.com/opinion/interview/us-monopoly-over-internet-must-go-says-louis-pouzin/article6370399.ece 18 https://www.internetsociety.org/sites/default/files/pdf/ISOC_NTIA_response_060707.pdf 19 https://www.internetsociety.org/sites/default/files/pdf/ISOC_NTIA_response_060707.pdf 20 [discuss] The NTIA/ICANN transitioning Process, By Seun Ojedeji, 29th March 2014, [email protected] 21 [discuss] The NTIA/ICANN transitioning Process, By Seun Ojedeji, 29th March 2014, [email protected] 22 https://www.internetsociety.org/sites/default/files/pdf/ISOC_NTIA_response_060707.pdf 23 Cauldron part2: Is the names IANA compatible with the others? By Milton Mueller, 19th Oct 2014, http://www.internetgovernance.org/2014/10/19/cauldron-part-2-is-the-names-iana-compatible-with-the-others/ 24 Cauldron part2: Is the names IANA compatible with the others? By Milton Mueller, 19th Oct 2014, http://www.internetgovernance.org/2014/10/19/cauldron-part-2-is-the-names-iana-compatible-with-the-others/
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David Johnson expresses concern25 that there may be abuse of IANA function (using the power over the root zone to impose top down rules) if ICANN staff imposes rules on new gTLD registries, in the absence of consensus. Further stating various legal issues are cropping up due to the new gTLD policy and that ICANN may need a police force, an anti-trust enforcer, or a general purpose internet governance body.26 Jovan Kurbalija27 shares, the new gTLD process also faces concern due to cultural, geographic and linguistic issues. For example, .amazon request, which had been submitted by online retailer Amazon was stopped amidst strong criticism from the Latin American countries, represented in ICANN's Government Advisory Committee (GAC). There is a similar concern with the application of .wine/.vin. There are concerns how ICANN would manage collision between non-DNS domain names and ―real‖ domain names (such as .onion, .local etc.).28 Also, as any organization can apply for a new gTLD registry, there are concerns29 w.r.t protection of trademarks and increasing cases of cyber squatting in the new gTLD process. According to Mueller30, since ccTLD‘s only rely on ICANN for updating their data on the global root zone, there are concerns on how ICANN handles re-delegation requests, as ccTLDs would not want ICANN to have any more centralized power over them. Human Rights
Council of Europe31 raises concerns relating to human rights and the right to freedom of expressions while deciding new gTLDs. They fear a balance between economic interests and other objectives of common interest, such as pluralism, cultural and linguistic diversity is not being maintained. Rebalancing of human rights and the right to private life pertaining to processing and retention of data and public access to personal data in the WHOIS database is also one of their concerns.32 Number Related
Developing countries have concerns33 on how ICANN allocates IP blocks. In the early days when IPs were allocated on first come first basis, nearly 80% of the existing IPs were
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25 David Johnson, 24th March 2014, http://1net-mail.1net.org/pipermail/discuss/2014-March/003106.html 26 http://www.europeaninstitute.org/index.php/194-european-affairs/ea-march-2014/1862-perspectives-us-plans-to-divest-control-over-internets-icann-dilemma-for-some-european-registries 27 An introduction to Internet Governance , By Jovan Kurbalija 28 http://www.europeaninstitute.org/index.php/194-european-affairs/ea-march-2014/1862-perspectives-us-plans-to-divest-control-over-internets-icann-dilemma-for-some-european-registries 29 http://www.mondaq.com/unitedstates/x/303058/Trademark/New+Generic+TopLevel+Domains+Will+Create+New+Trademark+Issues+The+Trademark+Clearinghouse+Can+Help 30 Cauldron part2: Is the names IANA compatible with the others? By Milton Mueller, 19th Oct 2014, http://www.internetgovernance.org/2014/10/19/cauldron-part-2-is-the-names-iana-compatible-with-the-others/ 31 Council of Europe 's Report: ICANN‘s procedures and policies in the light of human rights, fundamental freedoms and democratic values, http://www.coe.int/t/informationsociety/icann-and-human-rights.asp 32 Council of Europe 's Report: ICANN‘s procedures and policies in the light of human rights, fundamental freedoms and democratic values, http://www.coe.int/t/informationsociety/icann-and-human-rights.asp 33 http://en.wikibooks.org/wiki/Internet_Governance/Internet_Governance_and_Development
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allocated in North America. Currently, when the IPs are allocated to RIR's based on demonstrable need, there are still concerns that inequality persist in the allocation process. While the demand for IPs is still higher for developed countries, in a few years, the requirement for IPs would be more from areas which are still not connected and lesser developed. Current IP allocation and management process should ensure that numbers are uniquely and uniformly available across the globe, without any regional or community biases. The creation and management of orderly secondary IPv4 market is seen as a controversial issue in the RIR space. According to David Conrad, CTO ICANN 34 this issue is too big for RIRs to manage independently. According to Mueller,35 regarding the approach taken by RIR‘s in formulating a proposal, while it seems to be a bottom-up approach, however the whole process is under the tight control of the RIRs‘ secretariats. Each RIR has their own processes and interests and lack sufficient interest in formulating any process. Mueller36 is concerned over the slow decision making and the multiple steps involved. Thus, decision making once at regional level and then at global level, duplicates work. He also believes, the current numbers regime is imperfectly integrated with the ICANN regime. NRO is neither truly incorporated entity and lacks any global oversight or appeals mechanism,37 He is concerned that RIR‘s and ICANN share a very informal relationship.38 Protocol
Mueller expresses concerns39 over the relationship between ICANN and IETF (RFC2860) stating that firstly, as this relationship is based on a MoU, it is not considered a formal contract. Secondly, the status of IETF as a principal in the IANA contract should be strengthened in order to have a balanced relationship, which would also make ICANN more accountable. Just Net Coalition40 is concerned that the Internet technical standards system does not have any overarching public oversight and is dominated by US and global business interests.
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34 34 http://en.wikibooks.org/wiki/Internet_Governance/Internet_Governance_and_Development 35 The cauldron begins to bubble: Update on the IANA, By Milton Mueller, Dated Oct‘12, 2014, http://www.internetgovernance.org/2014/10/12/the-cauldron-begins-to-bubble-update-on-the-iana-transition/ 36 The cauldron begins to bubble: Update on the IANA, By Milton Mueller, Dated Oct‘12, 2014, http://www.internetgovernance.org/2014/10/12/the-cauldron-begins-to-bubble-update-on-the-iana-transition/ 37 The cauldron begins to bubble: Update on the IANA, By Milton Mueller, Dated Oct‘12, 2014, http://www.internetgovernance.org/2014/10/12/the-cauldron-begins-to-bubble-update-on-the-iana-transition/ 38 The cauldron begins to bubble: Update on the IANA, By Milton Mueller, Dated Oct‘12, 2014, http://www.internetgovernance.org/2014/10/12/the-cauldron-begins-to-bubble-update-on-the-iana-transition/ 39 The cauldron begins to bubble: Update on the IANA, By Milton Mueller, Dated Oct‘12, 2014, http://www.internetgovernance.org/2014/10/12/the-cauldron-begins-to-bubble-update-on-the-iana-transition/ 40 Governing the global Internet – is the status quo the only option? 28th Oct, 2014, http://justnetcoalition.org/sites/default/files/ITU_PP_2014_Stmt2.pdf
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AN OVERVIEW OF PROPOSALS FOR THE IANA
TRANSITION
As mentioned in the introduction, the NTIA announced41 in March 2014, its ―intent to transition key Internet domain name functions to the global multistakeholder community‖. It entrusted ICANN with the responsibility to convene stakeholders to develop a transition plan to replace the NTIA role in the IANA functions. Soon after, ICANN initiated a discussion process and called for public inputs to develop a transition process. The feedbacks also referred to the necessity of ensuring accountability of ICANN in reference to the transition. The IANA Stewardship Transition coordinating group (ICG) was set up with responsibility of preparing the transition proposals. It asked the "operational communities" of IANA to undertake consultations and recommend a transition proposal. The final proposal was to be developed on broad consensus. It would be based on proposals prepared by the Names, Numbers and Protocol communities, with subsequent comments from the larger community. A Cross-Community Working group (CWG) was set up to develop the proposals on Naming Related Functions. The protocol and number communities, viz The Internet Engineering Task Force ( IETF) working group called IANA PLAN and Consolidated RIR IANA Stewardship Proposal Team ( CRISP), were operational and have submitted their final proposals4243 to ICG. The IETF proposal argues that no new organisation or structures are required since the current system has been working well. The CRISP team similarly recommends continuing with ICANN as IANA Functions Operator for the numbering services. The CWG is yet to submit their final proposal and community members are discussing various options. Moreover, they would depend on the CCWG- Accountability team‘s proposal on improving ICANN accountability. CWG in the initial draft proposal
44 recommends that ICANN should continue managing naming functions post the IANA stewardship transition. It proposes the separation of ICANN as a policy body from the IANA Functions Operator. It also suggests putting in place ICANN accountability mechanisms and other improvements, before the actual transition. The proposal includes replacement of NTIA oversight by creating four structures:
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41 http://www.ntia.doc.gov/press-release/2014/ntia-announces-intent-transition-key-internet-domain-name-functions 42 http://datatracker.ietf.org/doc/draft-ietf-ianaplan-icg-response/?include_text=1 43 https://www.nro.net/wp-content/uploads/ICG-RFP-Number-Resource-Proposal.pdf 44 Cross Community Working Group (CWG) on Naming Related Functions Draft Transition Proposal, Refer Summary of the transition proposal, 1st December, 2014, Link: https://www.icann.org/public-comments/cwg-naming-transition-2014-12-01-en
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Contract Co.- a non profit body which would contract with ICANN to carry out the IANA function;
Multistakeholder Review Team (MRT)- comprising of selected representatives from the community;
Customer Standing Committee (CSC) having representatives from all communities and individuals; and an
Independent Appeals Panel (IAP).
Subsequently based on inputs received on the draft proposal, a discussion document45 was
released which discusses two types of transition models viz. the ―External to ICANN‖ (Contract Co, and External Trust) and the ―Internal to ICANN‖ (Internal Bylaw and Internal Trust) models.
The ―internal to ICANN‖ model envisages that ICANN permanently manage the IANA functions on the basis of undergoing reforms developed by the CCWG on accountability to provide checks on the ICANN board and detail a process to remove the IANA functions if needed.
The ―external to ICANN‖ model on the other hand proposes to create a shell Contract Co which will replace NTIA and will enter into a contract with the IANA functions operator viz. ICANN. The Contract Co. will be guided by MRT. Both the models however include mechanisms to ensure that the IANA functions can be separated from ICANN through the intervention of the above-mentioned MRT, and CSC and IAP. A Hybrid Proposal is also currently being discussed,46 by the CWG naming community. In this model, post the transition, the ICANN IANA functions will be transferred to Post Transition IANA (PTI) and a community board comprising of representatives from the three communities will oversee the PTI operations. This model proposes- in lieu of MRT- a PTI board having representatives from RIRs and IETF. The IAP and CSC of the earlier model remains while CSC ensures that the SLA/MoU between ICANN and Post Transition IANA are met. This model adds no new architectural considerations. There are three variations of this model, which are being debated:-
Hybrid ICANN subsidiary model- IETF and RIR have increased accountability and seats on community board, oversight by all operational communities at the operational level.
Hybrid shared services arrangement between ICANN, IETF and RIR: Here each of
the communities has shared community oversight, to make the structure less susceptible to capture. There is separation between policy development and policy
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45 Cross Community Working Group (CWG) To Develop An IANA Stewardship Proposal On Naming Related Functions Discussion Document for ICANN52 Singapore February 2015, Link: https://community.icann.org/download/attachments/49351404/CWG-SingaporeDiscussionDocument-Final.pdf?version=1&modificationDate=1422998880000&api=v2 46 https://docs.google.com/document/d/1SvKDEIaeHdre3BQXHNe1K3hCA95dsFWqWAz2Kg5YZCU/edit?pli=1
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implementation; all three parties must agree for substantive changes in PTI governance.
Figure: ICANN Subsidiary Model47
Figure: Shared Services Arrangement model48
Free standing model: Here, ICANN, RIRs and IETF have separate agreements with PTIA and have equal accountability. This is intended to create a higher degree of separation between policy development and implementation.
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47 https://docs.google.com/document/d/1SvKDEIaeHdre3BQXHNe1K3hCA95dsFWqWAz2Kg5YZCU/edit?pli=1 48 https://docs.google.com/document/d/1SvKDEIaeHdre3BQXHNe1K3hCA95dsFWqWAz2Kg5YZCU/edit?pli=1
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Figure: Free Standing model49 Analysis of the models being discussed at CWG
Currently the proposals being debated by the CWG naming community include the internal model, trust model (where a trust would be created in place of Contract Co. to enter into contract for managing the IANA functions), external model, hybrid ICANN subsidiary model, hybrid shared services arrangement model and free standing model. The policy-making community in all the proposals remain unchanged (ICANN, RIRs, IETF). However, the models differ in terms of the contracting organizations.
The internal-to-ICANN proposal envisages contracts with existing bodies like RIRs and IETF while the internal trust model suggests a board of Trustees, however it is still unclear on specifics of its Board of Trustees – its composition, selection process etc.
The external-to-ICANN model suggests contracts with Contract Co. RIRs and IETF,
The three hybrid models suggest contracts with GNSO, ccNSO; RIRs and IETF.
Similarities and differences amongst the different proposals being discussed by CWG
Community: IANA operator: IANA department is the operator, in the internal, trust and
external models. While the IANA department is operationally separated in the hybrid subsidiary model, it is functionally separated in the hybrid shared services arrangement while structurally separated in the freestanding model.
IANA Functions: While ICANN is proposed to manage the IANA functions in the internal, trust as external model, the hybrid models propose IANA (termed as Post Transition IANA) to manage it.
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49 https://docs.google.com/document/d/1SvKDEIaeHdre3BQXHNe1K3hCA95dsFWqWAz2Kg5YZCU/edit?pli=1
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Jurisdiction: It is still unclear of the hybrid models, the other models propose jurisdiction under Californian law.
Structure of the entity: All the models except the free standing model propose a non-profit structure.
Ownership: The internal and external models do not address ownership.
However, in the hybrid subsidiary model, it will be with ICANN and in hybrid shared model, it will be Partially-owned by contracting organization.
IETF in its proposal
50 to ICG on the IANA protocol parameters registries, suggests continuing with the same organisations/or structures post the stewardship change of NTIA. It points out, however, that, in absence of the NTIA contract, new arrangements may be needed to realize the IETF community's expectations.
The CRISP team, of the Internet Number Community, in their proposal51 to ICG, suggests that ICANN could continue as the IANA functions operator for the numbering services post signing a new agreement with the five RIRs and be referred as the IANA Numbering services operator. Any IPR related to the IANA services would remain with the community. CRISP team suggests establishing a service level agreement with IANA numbering services operator. It also proposes setting up a review committee, with representatives from all RIRs. Such a committee would appraise the Executive Council of the Number Resource Organisation52 (NRO) on the IANA functions operator‘s performance and meeting of identified service levels. In their proposal the number community suggest that the IANA trademark and IANA.org should be transferred to an independent entity prior to the transition. However the protocol community has not suggested anything of that nature. Post evaluating the proposals of the number and protocol community, the ICG sought clarification53 from both on the issue of IANA trademark and iana.org domain name. It has asked if the proposals could be modified and reconciled. The number community has responded54 to ICG stating that they do not observe any incompatibilities between the two proposals. Their proposal does not regard it as mandatory to transfer the trademark and domain of iana.org to IETF trust or any other specific entity and the protocol proposal does not explicitly oppose it. ____________________________________
50 http://datatracker.ietf.org/doc/draft-ietf-ianaplan-icg-response/?include_text=1 51 https://www.nro.net/wp-content/uploads/ICG-RFP-Number-Resource-Proposal.pd 52 NRO is Number Resource Organization which coordinates between RIRs and ICANN. 53 : Alissa Cooper on behalf of the ICG, IANA Stewardship Transition Coordination Group Responds to Submitted Proposals, 9th February 2015, Link: https://www.icann.org/news/announcement-2015-02-09-en 54 email Re: [NRO-IANAXFER] Question from the ICG, from Izumi Okutani on behalf of the CRISP Team to ICG, February 21st, 2015
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The initial community feedback reiterated the need of improving the transparency and accountability of ICANN before the transition. ICANN then published a proposed process on Enhancing ICANN Accountability.55, Based on community feedback, originally ICANN had proposed two groups on Accountability and Governance.56 However, it was later modified57 into a single Cross Community Working Group (CCWG) with two work steams. The first one is responsible for drafting a mechanism for enhancing ICANN accountability, which must be in place before the IANA stewardship transition. The other is addressing accountability topics for which a timeline may extend beyond the IANA Stewardship Transition. Work is currently underway on the same. The CCWG Accountability group is deliberating on a wide array of corporate governance changes to make ICANN, especially its policy making process more accountable. These include, changes in the bylaws, restricting ICANNs mission and scope, improving the appeals mechanism, etc. However, the timelines for approving and implementing these changes are yet to be decided. However, for any change to be implemented, it needs the approval of ICANN board.
Figure: A high-level overview of the IANA Stewardship Transition and Enhancing ICANN Accountability Processes58 ____________________________________
55 https://www.icann.org/resources/pages/enhancing-accountability-2014-05-06-en 56 https://www.icann.org/resources/pages/process-next-steps-2014-08-14-en 57 https://www.icann.org/news/announcement-2014-11-05-en 58 https://www.icann.org/en/system/files/files/iana-stewardship-accountability-07jan15-en.pdf
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The community members proposed several alternative proposals and approaches for the IANA transition. For example:
Internet Governance Project (IGP)59 suggests the following underlying principles for the transition,
o separating the root zone file modification from policy-making, o not internationalizing political oversight, o aligning incentives to ensure the accuracy and security of root zone
maintenance, and o de-linking IANA globalization from broader ICANN reforms.
IGP proposes,
creating a new entity, DNS Authority (DNSA), to manage the IANA functions related to the DNS root zone and associated databases,
moving IANA functions related to protocol parameters to the IETF and retaining IP address-related functions with ICANN. The DNSA would be a non-profit body, with no policy authority, controlled
by a consortium of TLD registries and root server operators. It would have a contract with ICANN. The proposal also calls for MoU between multiple principles, ICANN & DNSA.
Just Net Coalition (JNC) suggests60 dividing the IANA functions such that:
IETF secretariat manage the protocol parameters, NRO manage the IP addresses, a new entity (which could be a Swiss non- profit association) having members
from the gTLD and ccTLD community, manage the root zone file management,
ICANN manage the gTLDs while ICANN or new entity manages the ccTLDs.
Association for Proper Internet Governance supports61 a proposal of the International Ad Hoc Committee (IAHC) (a bottom up multistakeholder group which ISOC and others sponsored for discussions) for a Memorandum of Understanding (MoU) that would allow for the creation of an organisation called INROOTS
Which will be a non-profit intergovernmental treaty based organization,
Where private sector will manage technical and operational matters,
Governments will provide supervisory function,
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59 Roadmap for globalizing IANA: Four principles and a proposal for reform, By Milton L Mueller, http://www.internetgovernance.org/wordpress/wp-content/uploads/ICANNreformglobalizingIANAfinal.pdf 60 Just Net Coalition: Comments on the IANA transition and ICANN accountability [Revised] (July 2014); http://justnetcoalition.org/statement/comments-iana-transition-and-icann-accountability-revised-july-2014 61 Roadmaps for further evolution of Internet governance, By: Richard Hill, http://www.globalmediapolicy.net/sites/default/files/Roadmaps%20for%20further%20evolution%20of%20Internet%20governance.pdf
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Civil society will be able to provide inputs to government or INROOTS,
Will preferably outsource root server management to ICANN,
The policy decisions for number will be managed by RIRs, with IAB & IETF in liaison with ITU-T.
InternetNZ
62 offers the diagrammatic representation below of the existing IANA functions, organisations managing the functions, to facilitate discussion on what aspects is not part of the transition and share the wide range of solutions available for the institutional aspect of the new settlement.
Figure Diagrammatic representation of Proposed ICANN model by InternetNZ
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62 ICANN/IANA:'Role'and'Structural'Considerations, March 24th, 2014, http://www.internetgovernance.org/wordpress/wp-content/uploads/2014-03-ICANN-IANA-Role-Structures.pdf
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Figure Diagrammatic representation of Proposed IGP model by InternetNZ
Figure Diagrammatic representation of new oversight entity and structural separation by InternetNZ
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Figure Diagrammatic representation of new policy entity and structural separation by InternetNZ
Figure: Diagrammatic representation of new policy entity(2) & structural separation by InternetNZ
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Figure Diagrammatic representation of multiple policy entities and structural separation by InternetNZ The diagram highlights:
• The ICANN proposal to SO/AC chair (ICANN to manage the IANA operations and oversight);
• The IGP proposal, mentioned above; • Option to create a new oversight entity (ICANN to manage the policy
formulations and RIRs, IETF the protocols and a second entity the Root Zone management and IANA functions);
• Option of a new policy entity (i) with structural separation (having ICANN oversight, new entity to manage the policy formulations(common to all gTLD contacts and policies), RIRs and cctLDs; IETF the protocols and second entity the Root Zone management and IANA functions);
• Option of new policy entity (2) with structural separation (oversight by ICANN, new entity to manage the policy formulation (common to all gTLD contacts and policies), RIRs and cctLD and two entities within the RIRs for addressing local issues and global issues respectively);
• Option for multiple policy entities and structural separation (ICANN to manage oversight, new entity to manage policy formulation common to all gTLD contacts and policies, RIRs and ccTLDs to each have two entities one for setting and managing local issues and the other global and a separate entity to manage the RZM and IANA functions
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SUMMARY OF FEEDBACK FROM INDIAN
STAKEHOLDERS
As a part of this study, several stakeholders were approached for their views on internet
governance as well as IANA stewardship transition. These are included here to give a flavour
of inputs received.
Most respondents affirm India’s concerns about the current Internet governance
regime.
Government Several government respondents argued that not only India but across the globe, many countries are concerned that one country (US) has a unique role in internet governance. They believe governments should have a decisive say in issues of national security. However, what mechanisms would ensure this could be discussed. Civil Society Parminder Singh from IT for Change (ITFC), a civil society organization involved in internet governance issues believes that public policy matters must follow international norms and be subject to such oversight. Rishabh Bailey of Free Software Movement of India (FSMI) also shares concerns with the existing practices and feels that Government proposals such as UN Committee for Internet Related Policies (UN-CIRP) and at ITU Plenipotentiary 2014 suggest that the government too has similar concerns. Sivasubramanian Muthusamy of ISOC, Chennai, however observes that India‘s concerns are not as serious as made out. However its concerns lacked consistency and needed to be redefined after attracting unnecessary controversy. According to him, this is largely because of the involvement of multiple Ministries/Departments who have been unable to produce a consistent Internet Policy. In particular, Department of Telecommunications (DoT) sees issues from the perspective of Telecom companies or ITU positions. It is often closer to views expressed by China, Russia and in some instances, by South Africa. Ministry of External Affairs(MEA) often differs from historical positions taken by the Department of Electronics and Information Technology (DeitY). MEA seems not to be in tune with the present realities and with the global Internet Policy climate. In the normal course, Others According to Pallavi Bedi and Chaitanya Ramachandran from Amarchand & Mangaldas & Suresh A. Shroff & Sons, at a high level, Government of India (GOI) historically supports the multilateral or UN form of policy making, as various government departments have been part of organisations in UN frame work. Moreover, the multistakeholder process has seen dominance of western governments and companies while India has failed to exert its voice
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Business Vikram Tiwathia of Cellular Operators Association of India (COAI) argues that no one single country should lead in internet governance. India's interest lies in joining friends and world leaders. He suggests that industry needs to engage more with the government or the India MAG on this subject. He favours a structured approach to evolving Indian positions, after taking the views of stakeholders, like what TRAI does in its consultations. Respondents assert importance of the transition. Government A government respondent argues that there are two issues of utmost importance. First whether, the transition will be real or only in name. Second, if it is real then how does Indian government ensure its participation in matters of strategic importance to its goals. All other issues are secondary. Civil Society Sunil Abraham of CIS India argues that the transition is important for India and other nations because of the power that ICANN and global domain names and numbers industry have over governance. For example, what ICANN has done in internet governance over the last few years and what more it can do, is probably many times more than what Indian government has done. It is important to be aware of this transition. India should have a clear position on what it wants and the end state of overall India‘s interest with global public interest. Security is a concern for India. Civil Society According to Bailey further cyber warfare, security of critical infrastructure, security of data of businesses, citizens and governments are all concerns for India. Muthusamy suggests, India could have native and original thinking on matters pertaining to Security. Several traditionally liberal countries have recently deviated from their historical approaches and drastically altered the Civil Liberties framework. India could seek to inspire a balance and help design proportionate measures to deal with security issues. Role of ICANN in Transition
Concerns about ICANN’s conflict of interest Civil Society While Muthusamy believes that, the process of transition is probably more elaborate than necessary. ICANN has been carrying out IANA functions, with an almost hands-off oversight function performed by NTIA. ICANN has proven capabilities in performing these functions. It requires little or no changes within its organization to continue to perform these functions. Bailey, on the other hand, feels ICANN‘s procedures are not inclusive and questions how ICANN, which is in charge of the current system can be given the responsibility to oversee the transition process He also believes that it is critical to ensure external accountability of ICANN and its internationalization.
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Academic Dr. Rekha Jain from IIMA- IDEA Telecom Centre for Excellence agrees that there is conflict of interest in the current exercise since ICANN is operating the IANA functions. She furthers adds that India has hardly ever shifted its position to form a leadership. Others Bedi and Ramachandran feel, the concerns of India over the role of ICANN in the transition, stem from a conspiracy mindset that "ICANN means US control". This may be unfounded. Business Tiwathia further suggests that ICANN should adopt a more transparent and open approach. Decision making process
Most respondents feel that India would be anxious about NTIA’s support for
multistakeholder decision making process in the transition, as India has traditionally
preferred the multilateral approach.
Civil Society According to Bailey, governments (with appropriate participation of stakeholders in the policy framing process) should make public policy decisions. The processes he believes must be open, accountable and transparent Muthusamy observes that India‘s reluctance in fully embracing the multi-stakeholder process has been evident in open forums as well as in private conversations. It reflects a view that other stakeholders could provide inputs, but the Government will take the decision. This thinking i.e. ―Thus far, and no further‖, must change. Business Tiwathia advocates that India must support Multistakeholder decision-making. Role of governments in the transition
Most respondents feel that India is concerned with the guidelines laid out by NTIA for
the role of governments in the transition.
Civil society Bailey suggests that all governments should have an equitable role and representative institutions should be the ultimate arbiters on public policy matters, Muthusamy argues that Internet despite its origins as a US Defence project, evolved through efforts of the Internet Community, which has traditionally performed the governance function in the Multi-Stakeholder model. Many Governments are slow to embrace the idea of multi-stakeholder model of governance, often erroneously viewed, as a complete shift away from the traditional model of Governance where Governments make all the policy and retain all forms of control. However, multi-stakeholder merely seeks to expand the traditional model by bringing in the stakeholders directly to governance. Multistakeholder governance will be easy adopt if it is seen as the next step in the evolution of democracy,
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Business Tiwathia suggests that the role of governments should be equal as that of any other stakeholder in multistakeholder model. Others According to Bedi and Ramachandran, there is a view that Indian government favours UN style of decision-making. However, US government is equally adamant that the transition proposal cannot have any role of governments. gTLD related
There are concerns with the gTLD process.
Government There are concerns that ‗Indian‘ gTLDs e.g. .ram or yoga, are being appropriated by foreign companies. Others advocate more safeguards from abusive domain names. Respondents recognize that the potential opportunity for Indian industry in the new gTLDs was lost as players failed to realize it and cash in. Some argue that selling IPs and gTLDs at high prices goes against the goal, that Internet should be available to all. Civil Society Singh has concerns about the new gTLDs: while generic names such as ‗books‘ cannot be patented, a private company is allowed to control a gTLD like .book. He thinks the process is skewed. Abraham finds ICANN prioritizing gTLDS but not IDNs. According to him, alternative solutions are demonized. He questions why some countries have to be maximizing ICANN revenues. Muthusamy traces India's concerns to the fact that Top Level Domains happen to be operated by Domain enterprises based in the United States and Europe and this has not changed significantly even with the launch of the new gTLD process. India is not a victim of the design of the new gTLD process. The problem is that Indian companies have missed the opportunities in the new gTLD process and shown little interest. This could have been corrected if a government division was tasked to inform and encourage Indian enterprise to participate. Bailey feels that there are socio economic concerns, e.g. cost of gTLDs, There are also concerns about new gTLDs such as .amazon and the applicability of US based laws. Academic Jain observes that the government has raised concerns about gTLD allocations such as .ram. She further adds that there is insufficient awareness about price of gTLDs.
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Others However Bedi and Ramachandran feel India‘s issues stem from the low level engagement of the country in all such processes. Even domestic stakeholders and business entities are inadequately engaged. ccTLD related
There are few operational concerns about ccTLDs but more about ICANN’s
involvement.
Government There is an opinion that at the domestic end, there is space for more representation and participation in the ccTLD ecosystem especially since ccTLD would become important in the future and demand and growth of .in can increase several times over today‘s levels. Some respondents question the need for further gTLDs now with the ccTLDs already rolled out. One of the respondents from government raises concerns about jurisdiction in the current ccTLD system, Today, a ccTLD country is not considered as the ‗main party‘ but only an ‗interested‘ one. As a result, ICANN can offer a ccTLD to anybody if it is not a government. Moreover, the process for getting a ccTLD is very long and time consuming as ccTLD operators are asked for many documents. The accuracy of the Whois database is also a concern. He suggests that the ccTLD frameworks need reworking and the government should be treated as the main party or major stakeholder in decisions pertaining to ccTLD allocation. The ccTLD community should have more say in ICANN. Civil Society Bailey suggests, at the international level the ccTLD process should be exclusively for a country and should be non-alienable. Also, ccTLD principles control on domain name is a concern expressed by few respondents. Others Bedi and Ramachandran however believe ccTLD is running fine and that India need not have any concern. According to them, India‘s own and liberal policies have allowed the ccTLD market to grow and become profitable. Other respondents add that the prices are low allowing anyone to opt for a .in or .bharat domain name. More people must be encouraged to register these domain names through a marketing outreach. One respondent wants ICANN to clarify policy on the : a) procedure used to delegate and redelegate ccTLDs; b) Withdrawing permission from one ccTLD operations given to others. For example in Namibia, the ccTLD is operated by an individual, who does not want to give it up to the government. As per ICANN rules, existing ccTLD operators consent is required before the government can take charge of this ccTLD. There is no clear roadmap for ccTLDs. There have also been concerns about geographical names at second level.
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Accountability All respondents observe a link between ICANN accountability and IANA globalization
process and see ICANN accountability as a critical issue.
Government One of the respondents from government adds that whom ICANN would be accountable to is important, as are additional checks and balances. Global accountability principles need to be evaluated in depth. Civil Society According to Muthusamy the global multi-stakeholder community has a central role in the IANA transition debate and will determine the future of IANA. The entire process of transition is more elaborate than necessary since ICANN has proven capabilities in performing the IANA functions. It requires little or no changes within its organization to continue to perform these functions. Singh believes NTIA currently holds authority as a final publisher of registries and this oversight is being transitioned. Accountability cannot be oversight. Whoever holds the IANA functions has some authority, needs to have certain accountability and therefore have legitimate oversight by a global body. Therefore, Accountability should be enforceable to and through IANA, which therefore should be in such hands that can legitimately be the oversight of ICANN. Others Bedi and Ramachandran as well as Tiwathia believe that accountability of ICANN needs to be addressed prior to the IANA transition. There is need to review the role of VeriSign post the transition.
Some respondents argue that continuing the NTIA agreement with Verisign is incompatible while excluding the role of other governments post the transition. Concerns have been expressed regarding ICANN’s jurisdiction, lack of external
accountability, lack of transparency and disclosure policy and increasing mandate and
scope of ICANN.
IANA functions cannot be exercised without a certain authority. An external oversight is therefore necessary to prevent abuse or failure. Some respondents advocate external accountability of the ICANN Board. It could be based on pre-defined parameters e.g Who should ICANN Board directly be accountable to for its actions? Is a new institutional mechanism necessary, or can existing provisions be leveraged? Some respondent advocate restructuring of ICANN board based on gender,
geographical diversity, etc.
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Some respondents have argued that IANA stewardship transition and accountability
are twin tracks. So the exercise is about who the future IANA operator would be and its accountability. However, the current work on the accountability track seems solely focused on ICANN accountability . This gives the impression that the end result is predetermined and ICANN would invariably be the IANA operator. As IAB has final say when there is a conflict with regards to implementation of protocols in IANA, there are concerns about the accountability of IAB to the global community. There is a concern that the type of proposals which are being discussed by CWG and
ICG are skewed since they are overly committed to the timeline set by the US
government. Human Rights and Freedom over Internet Many respondents flagged human rights as a concern for India.
Civil Society Bailey adds that India has obvious concerns over violations of freedom of speech, cyber warfare, mass surveillance, etc. Muthusamy elaborates the existing framework of human rights applies sufficiently to Internet and an overlapping framework for Internet Rights is not required. There is need to suitably amend the Human Rights framework to embrace anything that pertains to the Internet and has not been sufficiently and unambiguously covered. Others Bedi and Ramachandran however feel that Government of India (GOI) has always been quiet about human rights. Where internet is concerned, they believe, India has had a poor track record on human rights. Privacy and free speech are a concern since the IT act is unconstitutional especially sec 66A. The government does not want to give up or change provisions that serve their interests. ICANN on the other hand is more aware of human rights. There are mixed views with respect to Freedom over Internet
Civil Society Muthusamy argues that by its original design, Internet is designed to allow the flow of communication end-to-end, without any intelligence in the centre (without any form of control or censorship in the centre). Thanks to this design, the Internet works, despite some narrow issues related to distortion of this freedom manifesting as hate speech or other forms of abuse. The larger good of freedom on the Internet far outweighs the issues presented by possible abuse of this freedom. It is good for the world to preserve the Core Internet Values. Bailey feels there are concerns with freedom over Internet as there is censorship of different kinds, breach of net neutrality principles, increasingly strict IP regimes etc. Business
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Tiwathia believes privacy issues seem to receive insufficient attention in India. He sees a need to raise a concern now, especially with the imminent emergence of Internet of Things. Jurisdiction
Most respondents accept concerns related to Jurisdiction.
Civil Society Bailey points, too many jurisdiction related issues ranging from requesting data (from service providers etc) to taxation. Muthusamy is of the opinion that, even though Internet is global, India‘s position on Internet jurisdiction is territorial. India‘s position is that the Government of India should be in a position to control the flow of Internet traffic within the country, or exercise Governmental powers over Internet usage within its borders, especially the usage of social media, and the messages published / exchanged through the social media. This needs to change to a more evolved position that Internet is a global ecosystem and that the absence of a centralized point of control is a core value of the Internet. Others Bedi and Ramachandran add that all nations have jurisdiction concerns. It is a problem in India considering western companies or US is mostly providing the services. So when government wants any data or content taken down it needs to go through the bureaucratic channels, which are slow processes and in nearly 99% of cases, the result is negative. A way to deal this issue, Bedi and Ramachandran suggest, could be for that India to consider being part of International treaties. Business Tiwathia too accepts this concern. ICANN as IANA operator
The role and authority of ICANN as a global policy maker for DNS is a concern for
India.
Civil Society Singh adds that for issues of public policy, rules and authority must be external to ICANN, since the latter can take care only of its internal – technical/ operational - aspects. He wants ICANN to be subjected to judicial oversight perhaps by experts or judges following international laws. Muthusamy however believes that the role and authority of ICANN as a global policy maker for Critical Internet Resources (CRI) ought not to be a concern for India, so long as ICANN is a global multi-stakeholder organization, gradually emerging to be free of disproportionate influence of any country or countries. ICANN is designed to be global. India must work towards ICANN improving its processes and its accountability mechanisms, so as to be fair for the global stakeholders.
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Business Tiwathia feels that the biggest concern regarding ICANN is the US oversight. Others Bedi and Ramachandran are concerned with ICANNs track record in handling issues in the recent past. They argue that in the Netmundial initiative, ICANN behaved inappropriately and artificially created a body with unilateral views. Secondly, ICANN was given a contract to manage the IANA functions however, the view coming today is that they believe IANA functions are ICANNs to manage. ICANN should be more open and inspire confidence in people Academic Jain adds that ICANN seeking proposal when it itself manages the functions is unacceptable and conflict of interest. She feels there should perhaps be a plurilateral body with multifunctional representation, with elected or selected nations from all across or a multistakeholder body which decides on terms of control, evaluation process of the inputs, etc. as there has to be some external references. IANA Root Server Management
ICANN competent to carry out technical operations but oversight and policy role need
improvement.
Civil Society The opinion is divided within civil society. Muthusamy sees little justification for India‘s concerns with ICANN's role in the oversight of IANA's operations, as the ICANN oversight is a step forward from the present unilateral oversight of the US Government. India could however have a view on how the ICANN oversight is constituted, and about how the ICANN accountability mechanism is designed to ensure fairness. These are issues currently being debated, by the global multi-stakeholder community, transparently, with a certain and definite degree of commitment and purpose. According to Bailey, there is justifiable concern about the legitimacy of ICANN managing global resources despite being a US body governed under US laws. He believes that procedures currently followed are not inclusive and have a democracy deficit. ICANN should be internationalized since accountability of ICANN is critical. Root zone too should be internationalized. Public policy decision-making he believes must be by a representative, democratic, accountable institution in an open and transparency manner. Others Lawyers Bedi and Ramachandran feel India should not have any issues with ICANN managing the IANA operations. Rather India should be more proactive in raising their concerns and issues on time as ICANN processes are very well laid out. Business Tiwathia believes that greater participation from India - atleast in the technical and policy level -would help address such concerns in future
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Respondents oppose the view that NTIA role is not policy but merely a matter of
implementation.
Government Most respondents believe that the NTIA function is a strategic one since US has final authority in the hierarchy of order in Internet Governance. Irrespective of it misusing the authority or not, it has power to authorize addition or deletion in the root file. NTIA today has strategic control. The contracts of NTIA with VeriSign or ICANN clearly indicate this power. Civil Society Abraham explains that NTIA deals with the market for domain names and numbers and governments, whose citizens and corporates might have invested in them, may want to be part of global regulation. There are policy concerns for governments who therefore want to be involved. There should be distinction between policy development, implementation and adjudication. This allows separation of power, a model followed in India. Most respondents believe that it matters to India who manages IANA functions and
how as well. In addition, what the ICANN end state is, when the transition takes places.
Others According to a respondent ICANN should be allowed to continue as the IANA operator only if there are measures taken especially related to accountability. Currently there is no one above the ICANN board of directors and that is the role played by NTIA. It is unclear who will perform the role if NTIA is taken out of the equation, How ICANN can be held accountable in future for anything it does is critical. The NTIA replacement, a respondent suggested, should not be based in US. He is unclear about the form it will take but suggests that it could be something like the NRO body, which has no corporate jurisdiction but is an international body. With respect to composition of such a body, it should comprise of people both from ICANN community and outside. He argues that the names community is talking about accountability and ICANN roles. Other areas are quite technical. But names and domain names is quite conflict prone and contentious area as the stakes are higher. Independence of IANA
Most respondents believe that India has concerns with the policy oversight of NTIA
over the IANA functions.
Civil society Even within civil societies, there are divergent views on the level of concern. Bailey observes that even if NTIA has not misused their power till now, however under extreme and extraordinary circumstances there is an opportunity or possibility to misuse their power. Singh adds that there have been various levels of concerns of the US oversight. US have declared they will give up executive authority, that is one level. However, so long as ICANN
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is still governed by US laws, the US controls remains. The only alternatives they feel are, either ICANN being shifted outside US or being provided legal/ jurisdictional immunity and incorporated under International laws. There should be accountability to larger society and for that, oversight should be from people outside and not inside. ICANN accountability should be to the world and external community. For example a forum of eight people should be formed comprising of people from different interest groups such as women's group, educators, media, health, specially-abled, etc. He believes, that the problem with current oversight is that it comprises of people from within the ICANN system or its community such as GNSO etc. Muthusamy regards this more as a symbolic concern than a concern arising out of any actual issues. He believes NTIA is in the process of conceding its role to the global Multi-Stakeholder community. Others Bedi and Ramachandran however believe India does not have been any issues at the operational level. The concerns related to ipv4 allocations have now been addressed. Even at policy level India should not be concerned. They believe that "if it is not broken don‘t fix it", as NTIA has done a decent job till now and the future is not clear. Mixed views on current arrangements where a private company (Verisign) is the Root
Zone Maintainer
Government There is a view that VeriSign as Root Zone Maintainer could lead to a single point failure. It is preferable to have an alternate system with collective responsibility of all stakeholders along with better check and balances Civil Society According to Muthusamy, NTIA has clarified that "aspects of the IANA functions contract are inextricably intertwined with the VeriSign cooperative agreement (i.e., authoritative root zone file management), which would require that NTIA coordinate a related and parallel transition in these responsibilities ". So the cooperative agreement is also likely to be under review and likely to be transitioned to the multi-stakeholder community when the current agreement expires in 2017. It appears that NTIA wants to successfully transition the processes as announced by Sep 2015 and then take up the RZM cooperative agreement. Verisign does not make policy, it provides the technical operations, and after possible transition to ICANN, ICANN is likely to be in-charge of RZM directives, and ICANN would also have the role of contractor to Verisign. It would be fair to accept the possibility of considering alternate bids for this technical service, if the need so arises. While Singh proposes that, a non profit entity should manage this function. He feels that root zone management can be managed by anyone. ICANN as the IANA operator could do it too. However, no third party company should manage it. Bailey proposes that it should be managed by an international body, with appropriate oversight and accountability mechanisms in place. What is critical, Bailey feels is ensuring an appropriate juridical framework to ensure such an institution is truly international and democratic in its functioning.
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Others Bedi and Ramachandran say they have not come across any Indian concern over VeriSign‘s role as Root Zone Maintainer. Even in India various tasks of the government are sub contracted to others. They only issue which they feel might crop up, is in the way in which VeriSign executes its task. However there have not been any grounds of concern till date. Academic Jain suggests that alternatives should be looked at through global competitive bidding. The process should be open to scrutiny, audited and auditable with oversight. Business Tiwathia suggests that a group or coalition should have oversight over and manage the root zone maintainer. This, he believes would build people‘s confidence. Proposed Transition Model
Few respondents have supported specific existing proposals, many offer outlines of
proposal that India should propose.
Government There is a concern that current proposals do not deal with jurisdiction and dispute resolution mechanisms. Any effective proposal for transition, whether complete or incremental, that ensures greater participation of Indian Government would be supported by India Civil society Singh further adds that India is still in a reactive mode, responding event by event. He feels, India should start looking at the big picture, improve overall understanding of the internet related public policy and technical issues and then devise a larger set of principles and strategy for the long run. He supports the proposal of Just Net Coalition, to some extent. Bailey is of the opinion that Internet is a global resource and should be in the hands of the global community and not in the hands of a single country. Global community has to sit together to identify what the issues are along with the most appropriate way to find an acceptable solution to a particular issue. He believes, there is a need for regulation of this space at both the international and domestic levels (for instance, we need rules on mass surveillance carried out by one state on another and equally we need strong domestic protections that ensure a citizens‘ rights are protected vis-à-vis the government). He further states ―Public policy decision making should be the responsibility of governments though the framing of policy should be open and transparent and take into account the inputs of all relevant stakeholders.‖ They broadly support the JNC proposal. Muthusamy advocates India evolving a national proposal by multi-stakeholder consultations. Abraham favours a non UN, Geneva based institution. He believes, policy development, implementation and adjudication should be separated. Most models proposed currently, he feels are incomplete. Moreover, ICANN is not a model of good governance. Its transparency mechanism is inadequate. In addition, ICANN has set up a complicated system of rents and certain organizations and businesses benefit commercially as does ICANN. Primary
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requirement of transparency is who is setting policy, what it is and how it is being set. At the moment the objective seems unclear and there is very little discussion on end state ecosystem. Most governments seem not to be saying anything or proposing alternatives. Others Bedi and Ramachandran, feel that India should support the IANA transition unless it 1) Goes against any of NTIA's mandate 2) Directly contradicts India's own policy interests. Academic According to a study by Jain ―Today there are no sustained activity or policy framework through which government can take decisions or come up with a proposal. Any Internet Governance process should satisfy certain legitimacy parameters, which may be categorized into (i) Participation, (ii) Agenda Setting and Decision-making Processes; and (iii) Outcomes. Any adopted process needs to be evaluated against the Perceived Legitimacy Framework outlined in the report.‖ She further adds, with the subject of internet governance becoming all pervasive, such activities should be carried on in an ongoing basis. She is of the opinion that a body should be established which has representatives from all stakeholder communities, who look, evaluate issues thoroughly for example what stage they are in who are the important stakeholders, its importance to India and then debate and decide the process to be adopted based on set parameters to come up with a legitimate framework using an open and transparent process with consensus of all bodies involved. However, this process should be an ongoing one. Most respondents feel that while India supports overhaul in the long run, as of now, it is
looking for incremental changes.
Civil society Bailey adds that it may be more realistic to go step by step. Singh is of the opinion that India is not looking for rearranging the complete existing architecture but in between. However, the time has come to reaffirm that public policy issues need clear resolution. Increasingly, there are numerous public policy issues of great important that arise from the technical management and naming or numbering allocation, with respect to the Internet. An appropriate global way to address these must be found. Muthusamy feels that if India takes a well mediated and balanced position, it constructively supports incremental change. However in the past, a multiplicity of actors from within Government, have expressed extreme, not-so-well-thought out positions to the surprise of the Internet Community in India and the world. Abraham expects end state to be dramatic and wants that it should be done in best way possible and not necessarily as an incremental change. The process should not be hurried. He would rather go slower towards an effective solution. Others Bedi and Ramachandran feel the government so far has been reactive to issues and want it to become more proactive as there is much at stake.
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There is some support also, for India to opt for incremental change in the current setup. Academic Jain is of the opinion that rather than trying to change systems in one go; India should participate in ongoing processes and create its own niche. Few people in the government believe that India would be taking a proactive position and India's position would be based driven by the agenda of Digital India. With over 50% outsourcing from India 3Million Indians are involved in this industry, Indian position has to reflect that India is a key global player. There are mixed views on what role if any, India or any other government should play
in oversight over IANA.
Government: One respondent from government is of the opinion that along with other players, Government too has a role to play, more so in matters related to security and public policy. Issues such as .amazon or .wine are political issues and wherever there are political issues, governments should have the most important role. The GAC should have more say in ICANN and its power should not be limited to advisory role, rather it should have a say in decision-making. Civil Society Singh is of the opinion that ICANN‘s process is vague with governments having an ad hoc role in GAC. Bailey feels that all governments should have an equitable role and representative institutions should formulate public policy. India should take lead with other developing countries with whom they have similar interests in ensuring a framework for democratized governance is put in place. Others Bedi and Ramachandran believe that India has to step up its engagement in ICANN especially in the GAC and take leadership position. ICANN does not seem to be enough priority for the government departments and there is an evident lack of engagement, while other developing countries like Iran, Brazil have been proactive. There are no clear policies of the Ministry and even the bureaucrats are not cleared to voice their views. There should be more interaction of the government with other stakeholders so that proper policies can be formulated within the country in an open and transparent manner. Currently there is almost minimal consultation and few which are held are closed door. Domestic stakeholders should not be kept in the dark of the position of the government. India should either have a strong Internet policy in place, or empower its bureaucrats to engage and express their views at international forums. Industry too needs to step up their engagement. Business Tiwathia believes government could take the initiative to engage with industry and other players. However government should not try to influence but instead allow internet to grow free through self regulation. It should help create an environment for investment in creating access to Internet in India, as the priority here is to get people to use Internet.
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There are respondents who regard that the existing GAC needs improvement
Government GAC is not seen as an effective instrument for governments to raise their concerns since it is only an advisory body. Moreover, since decisions at GAC are taken based on consensus, amongst approximately 160- 170 odd countries, it is very difficult to get issues raised or passed. There is a need to increase engagement from India - business, civil society, and others. Most respondents believe that while India may share the same position with Saudi
Arabia, Russia, China or Brazil, there are many areas where they have divergent views.
Government India cannot be clubbed with China or Saudi Arabia as India is a democratic nation, which guarantees human rights including freedom of speech, an open internet. The only common position relates to need for International jurisdiction. Countries broadly agree on names, numbers, technical protocols, day to day operations. India differs from China in information security and control but agrees with it on multilateral control. China and India too are very active in bodies such as ICANN yet do not endorse all views of the body. Civil Society Singh argues that in terms of freedom of expression India is largely on the sides of western countries. However when it comes to struggle for participation, economic, socio cultural, financial governance issues, India is closer to the traditional developing nations groups. As a result of moving between different blocks India has not been able to consolidate its position. Bailey states India is very different from countries such as Russia, China or Saudi Arabia. Our Constitutional framework ensures that we have a different type of governance structure to any of these countries. For political and other reasons, the issues facing countries such as China are also very different from India (largely as China has insulated itself from the rest of the Internet). India has the capacity to play an important role, particularly in representing the views of developing countries at the global stage. Abraham argues that distinctions between democratic and authoritarian governments have been removed by the Snowden revelations. If India , China, Russia or Saudi Arabia claim state control in internet governance they need to provide an detailed justification and alternative formulation. It is interesting that some of these nations on GAC, clearly indicate that they are not divorced from ICANN. India believes state is the enforcer of human rights however other governments might see the role of state to be dominating and regulating and come from that perspective. However, this does not indicate 100% overlap between these countries‘ approaches. Academic Jain however believes there has been no strategic approach.
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Indian IT and telecom industry has shown little interest in this subject. However, this is
changing.
Government The Indian IT industry is currently focused in development and consolidating their position. One respondent from the government feels that their involvement in matters pertaining to Internet governance is negligible as this subject is not a priority for them. It is important to bring them back to this discussion. There is a need for more Indian industry participation in bodies such as IETF task force. Indian organisations should have a more product-oriented approach; create indigenous software‘s and applications in local languages. There is also a view that industry is not aware of actual issues. There is little understanding of internet governance issues or of the business and strategic opportunities. Significantly, many government bodies complain that industry does not share any views when asked. Civil Society Singh argues that while Indian companies have begun to understand larger issues, However they take other stands for short term business interests. Bailey argues that there are differences in stances between big and small businesses in issue s such as net neutrality, freedom of speech, data security etc.. It all depends on where they do business; companies are concerned about data hacks etc. They are less familiar with internet governance. However, with increase in internet penetration the awareness is bound to increase.
Ministries in GOI are beginning to see internet governance from different perspectives
and are coordinating better than before.
Government There is a view that government‘s position on national security and cyber security is poorly formulated and lacks stakeholder inputs. The concern about US domination of internet has prompted support for a UN led approach. A respondent believes this is changing now since there is more coordination between the different ministries. Civil Society Singh explains, internet today has many issues - commercial, security, health, trade etc. and each department looks at it with different perspectives. He proposes a new setup or Internet division with new decision making body with experts at the earliest. He believes this could be combined with the work on the convergence bill. Bailey observes that he is not aware of the specific differences between government agencies. However, DOT traditionally looks at internet as a continuation of telecom. MEA looks at the broader picture. There needs to be more coordination between the different ministries to come up with a more reasoned and consistent stand, which can be explained to stakeholders in advance.There, should be far more discussion in public even while framing the government position. The government has traditionally supported multilateral approaches. However the approach has to be issue based, open transparent and accountable
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Absence of public dialogue before government takes decisions related to internet
governance.
Civil Society Abraham believes that even if Government cannot come out and discuss end state, it could possibly discuss or share the broad approach. Currently government departments either decide themselves or in consultation with few, without a public dialogue. Government should take advantage of the diverse expertise of stakeholders rather than each department pushing its own specific agenda. Many respondents propose that the government could possibly follow the TRAI model of Consultation paper, counter submissions, round tables etc. Abraham further adds that if this is done well and as per international standards, the quality of participation would increase. Bailey recommends more consultations with the populace. Approach of new government
Government One respondent believes the government is more open to collaborations, the multistakeholder model and for discussion with stakeholders. He feels greater decisiveness in relation to internet issues. Civil society Abraham however, is not sure. He has seen details on Make in India but little change on internet governance although there is more participation of better quality. The three departments MEA, DOT and DEITY have their voices and views. NSA and PMO are involved too. Whether they will be a fourth voice of diversity or unifying voice, it is still to be seen. Overall, there is no communication on the IANA transition. Government approach to multistakeholder model is unclear.
Government Many in government support the Tunis Agenda. There is however need for greater consultation even if government ultimately takes the decision. There are concerns that the global process is not inclusive and needs correction. The legitimacy of GAC too is questioned. It is a group for governments yet is it formed under the authority of a private entity. This can be corrected. They propose global norms for global entities and the UN agency and community to draft rules and constitutions. Solutions can be found by negotiating with ICANN to give the process legitimacy and to make it more transparent A respondent wants India to view multilateral or multistakeholder formulations as not mutually exclusive. He recommends an issue based approach to choose the best possible option.
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Others in the government believe that India is looking for a model that addresses national security concerns and is in line with public policy objectives. It should be simple and broadly acceptable internationally. In Multilateral process of policy formulation, care should be taken that it does not fall into the hands of despotic nations. Adequate consultation is important. Civil society Bailey is unsure of the government‘s position on Internet Governance although he accepts that India has traditionally been supporting multilateral model (for instance UNCIRP). He feels it is quite unlikely the government will change its position dramatically but might take a more cautious approach and tone down their stand. That said, the government is also increasingly reaching out to various stakeholders – particularly industry - in framing both domestic and international policy. On certain issues it is unlikely that the government‘s stance will change dramatically – for instance the role of governments in governance. He is happy that internationally, India has been ready to take unpopular stands. He believes that CIRP had some good ideas but the proposals were not well articulated or structured. India did not go all out to garner support from other countries. India could do much by being more engaged in the process, be consistent, get the support of domestic stakeholders and have a thought out proposal following an open, accountable and transparent process. Bailey reiterates Indian position should be issue based. Certain issues, for instance enforcing law, are domains of states / governments. Similarly to ensure no cyber warfare, there will have to be an international treaty – which means states having to enter into an agreement. Other issues, for instance framing technical standards, however, can be dealt with through more bottoms up methods. Para 35 of Tunis Agenda requires that all stakeholders act in accordance with their roles and responsibilities. Public policy decisions should be taken by peoples representatives. Even Marco civil which is lauded by everyone had inputs of all stakeholders which was then passed by the Brazilian parliament.Government has to play the role of power Mediator. However all governmental (and any other) process should be opened up – must be transparent, open, accountable. Inclusive participation is a must in all such processes. Singh believes Public policy issues should be decided under international laws. He believes India has not reacted, due to absence of strategy. He is hopeful that the government in some time would consolidate its views. He expects it to be in favour of multilateral approach, meaning adequate means to resolve public policy concerns, while protecting the current IG architecture for technical and operational matters. International Organisations, consulted for this report broadly recommended that government should be more open, consistent with their approach and encourage more representation in not only all the groups of ICANN but also other international forums. They urged that the relevant ministries work together to come up with a unified stance.
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DISCUSSIONS AND RECOMMENDATIONS
Discussions
The NTIA has asked ICANN to coordinate a process for interested stakeholders to develop a
transition proposal for an alternative stewardship of the IANA function. It is important to
recognize that NTIA has not explicitly sought a revamp of IANA or its parent ICANN. The
task of ICANN is therefore to find an alternative way of performing a function that ICANN is
currently carrying out under contract with the NTIA.
Developing countries like India have a critical stake in the success of the IANA function.
The IANA function has clear implications for the future growth and stability of internet. The
continued availability of sufficient IP addresses and the ability to undertake administration of
protocol parameters are key IANA responsibilities.
The transition has a bearing on India, including the Digital India programme. Growth of
internet usage has picked up pace, with roughly 250 million users. India‘s major IT
companies, who have been largely focussed on overseas markets, are increasingly keen to
address Indian markets. India‘s success in leveraging the Internet of Things will depend to a
great extent on the efficiency and independence with which IANA functions are carried out.
There is broad recognition that ICANN performed the actual tasks involved in the
IANA function responsibly and efficiently. No person who was interviewed for this report
expressed dissatisfaction with how ICANN carries out its operational responsibilities. There
is no evidence of a serious crisis in the performance of the IANA function or even of NTIA‘s
dereliction of its responsibilities or abuse of power.
IANA stewardship transition raises questions about the future of IANA functions.
Countries like India would need to identify risks that the new arrangements can pose to its
aspirations and strategic interests in the Internet domain.
The Indian government is right to seek parity. There is need to distinguish between a
government‘s legitimate demand for parity with its peers and the worrying possibility that
some authoritarian governments might use such ‗parity‘ to make it easier to control access or
content on the internet. There seems little attempt in the debate over internet governance to
treat these issues robustly.
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Concerns related to the IANA transition stem from potential abuse of oversight or
authority over IANA functions. All world governments do not currently enjoy equal
authority in internet governance functions. The India government‘s reservations about the US
governments‘ role (through NTIA) arguably stem more from this perceived lack of parity
between US and other countries. There is a discomfort that for example, final authority on the
continued existence on the root zone file of country top level domains (ccTLD) rests on a
single government even if the possibility of exercise of such authority seems remote.
IANA function stewardship must be equally distant from all governments. While a
multilateral body may not be necessary or acceptable, it is critical that the body that replaces
NTIA is and is seen to be sufficiently independent of all governments.
India must separate operational issues from policy concerns. As outlined earlier in this
report, several options are currently under discussion for the alternative to the NTIA role post
the IANA transition. However, a key to protecting India‘s long-term interests in operational
matters is to ensure that policy function is carried by an organization acceptable to a suitably
representative set of countries.
ICANN faces a conflict of interest as it seeks to coordinate inputs in to the process for
the IANA stewardship transition. This has been pointed by several stakeholders63. While
the ICANN‘s current process is transparent and open to all interested stakeholders, it is
important to underline that it is an interested party when it comes to decisions. ICANN
cannot, directly or indirectly, be ―judge in its own cause‖. It would be difficult to justify if
ICANN was to influence what reaches those who will decide the future stewardship of the
IANA function.
ICANNs role and accountability are especially relevant to plans for an alternate of
stewardship of IANA function. For the transition to have meaning, the stewardship or
authority for IANA functions, mentioned earlier in the report, must change significantly to
address the current discomfort with its existing relationship with and accountability to the US
government which retains the right to terminate the Affirmation of Commitments (AoC).
Indeed the perceived credibility of the exercise depend on the degree to which internet
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63 NTIA to give up control of the Internet‘s root By Pranesh Prakash, Center for Internet & Society, March, 2014, http://cis-india.org/internet-governance/blog/ntia-to-give-up-control-of-internets-root
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governance including the IANA function are separate from any particular government
whether US, India or any other country.
The concerns over accountability of IANA functions stem from the perception about the
limits of ICANN’s accountability. These are relevant, despite the stakeholders‘ confidence
in the competence of ICANN.
The accountability of ICANN is an issue for the user communities as well as
governments. The user community – whether individuals, industry or other non-government
entities - also have a stake in a fair and responsive ICANN that controls critical internet
resources such as IP addresses and the DNS system. Much like what they expect from an
agency that controls resources such say minerals, radio frequencies etc. However, ICANN
also administers resources that government use today or may do so in future.
ICANN has de facto regulatory authority over government entities outside the US
where it is headquartered. For instance, it has the critical authority to include ccTLDs in the
root zone file. It is thus an arguably, unique private – albeit non-profitable - body with such
potent authority. India‘s government, like several others, has frequently advocated change.64
External accountability of ICANN is therefore a key requirement to the IANA function
and otherwise. ICANN has functions and responsibilities that extend beyond the US. It
reflects a hierarchy in governance of internet, which is antithetical to the functioning of the
internet itself. It is untenable that an agency, with operations on such an international scale,
lacks adequate legal accountability across US borders. The absence of external/international
oversight over such a body would be an anomaly.
IANA operator should be accountable to all who its decisions directly impact. ICANN,
which performs this role currently or its successor, will lack credibility if the agency of last
resort for grievances and disputes is ICANN itself or an entity that it is closely associated
with it in any administrative, commercial or any other way.
ICANN can continue to be an autonomous body despite having external accountability.
There is a strong case for the new arrangements to prohibit day-to-day interference in ICANN
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64 Cases in point: India‘s proposals for UNCIRP and its inputs in ITU‘s recent plenipotentiary meeting in Busan in South Korea, in 2014.
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functioning, by any person or agency inside or outside government. ICANN performs above
all an important technical task where competence and independence are paramount.
IANA stewardship transition poses no complex operational problems. As has been
pointed out, NTIA has little role in day-to-day role in ICANN‘s specific IANA function or
indeed other functions. NTIA‘s role despite being a political irritant to other governments is
largely symbolic.
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Recommendations
1. A credible independent body must replace NTIA in its stewardship of the IANA
function. The body must:
Be subject to international law.
Have an executive board composed of independent persons of expertise and
reputation.
Have an advisory board to address policy matters.
Have a constitution that prevents capture by any state player.
Obliged to act transparently and proportionally.
Be free to design its own structure and work rules, subject to above
principles.
Able to raise its own resources including funding, without any dependence on
any government.
Not be bound to accept directives other than from a duly constituted board.
2. India must prioritize policy issues over operational issues concerns in the IANA
function.
3. India must seek higher levels of accountability for ICANN, not its replacement.
4. Before taking a position on internet governance matters, India must undertake
serious consultations with its large IT industry, which has been relatively silent
on issues related to internet governance.
5. India must undertake steps to create awareness within government and outside
about internet governance matters which are growing increasingly in
importance.
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6. India must recognize its stake in a single and smooth functioning internet,
enabled by the existing ‘multistakeholder’ bodies involved in the IANA function.
7. India must reject proposals, which lack acceptable levels of accountability of
ICANN.
8. India must recognize that a successful Digital India programme can radically
increase its stake in internet governance including the IANA functions.
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ANNEXURE
ABBREVIATIONS
Abbreviations Full Form
ALAC At-Large Advisory Committee APNIC Asia Pacific Network Information Centre AS Autonomous System ASN Autonomous System Number ASO Address Supporting Organization ccNSO Country Code Name supporting Organisation ccTLD Country Code Top Level Domain Name CCWG Cross Community Working Group on Enhancing ICANN
Accountability CRISP Consolidated RIR IANA Stewardship Proposal Team CWG Cross Community Working Group on Naming DNS Domain Name System GAC Governmental Advisory Committee GNSO Generic Name Supporting Organization gTLD Generic Top Level Domain Name IAB Internet Architecture Board IANA Internet Assigned Numbers Authority ICANN Internet Corporation For Assigned Names and Numbers ICC International Chamber of Commerce ICG IANA Stewardship Transition Coordinating Group IETF The Internet Engineering Task Force IGF Internet Governance Forum IP Internet Protocol ISOC Internet Society LIR Local Internet Registries NMI NETmundial Initiative NRO Number Resource Organization NTIA National Telecommunications and Information Agency PEG Accountability & Governance Public Experts Group RIR Regional Internet Registries RSSAC Root server System Advisory Committee SSAC Security and Stability Advisory Committee sTLD Sponsored Top Level Domain Name TLD Top Level Domain Names WSIS World Summit on Information Society
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KEY INTERNET GOVERNANCE ORGANIZATIONS
Organization Responsible For
Commission on Science and Technology for Development (CSTD)
The CSTD65 is a UN body and a subsidiary of Economic and Social Council (ECOSOC). It was established to provide the General Assembly advice on relevant issues through analysis and appropriate policy recommendations or options.
CSTD Working Group on Improvements to the IGF (CSTDWG)
CSTDWG66 has been active since 2011 and have had 5 meetings since then. The Working Group report made 15 recommendations with regard to five specific areas, namely: Shaping of the outcomes of IGF meetings. Working modalities of the IGF, including open consultations, the Multi-stakeholder Advisory Group (MAG) and the Secretariat Funding of the IGF Broadening participation and capacity-building Linking the IGF to other internet governance-related entities.
Internet architecture Board (IAB)
The IAB67 is responsible for defining the overall architecture of the Internet, providing guidance and broad direction to the IETF. The IAB also serves as the technology advisory group to the Internet Society, and oversees a number of critical activities in support of the Internet.
Internet Engineering steering Group (IESG)
The IESG68 is responsible for technical management of IETF activities and the Internet standards process. As part of the ISOC, it administers the process according to the rules and procedures which have been ratified by the ISOC Trustees. The IESG is directly responsible for the actions associated with entry into and movement along the Internet "standards track," including final approval of specifications as Internet Standards.
Internet Engineering Task Force (IETF)
IETF69 is an open international community of network designers, operators, vendors, and researchers concerned with the evolution of the Internet architecture and the smooth operation of the Internet. The actual technical work of the IETF is done in its working groups, which are organized by topic into several areas (e.g., routing, transport, security, etc.).
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65 http://www.unctad.info/en/CstdWG/ 66 http://www.unctad.info/en/CstdWG/ 67 http://www.ietf.org/glossary.html#IAB 68 http://www.ietf.org/glossary.html#IESG 69 http://www.ietf.org/about/
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Internet Research Task Force (IRTF)
The IRTF70 promotes research of importance to the evolution of the Internet by creating focused, long-term Research Groups working on topics related to Internet protocols, applications, architecture and technology. The IRTF is managed by the IRTF Chair in consultation with the Internet Research Steering Group (IRSG).
International Telecommunication Union (ITU)
ITU71 is the United Nations specialized agency for information and communication technologies – ICTs. ITU allocates global radio spectrum and satellite orbits, develop the technical standards that ensure networks and technologies seamlessly interconnect, and strive to improve access to ICTs to underserved communities worldwide. ITU has both public and private sector membership comprising of 193 Member States, ICT regulators, leading academic institutions and some 700 private companies.
Internet Research Steering Group (IRSG)
IRSG72 is responsible for steering the IRTF and provide good conditions for research carried out by IRTF.
Number Resource Organization (NRO)
The NRO73 is a coordinating body for the five Regional Internet Registries (RIRs) that manage the distribution of Internet number resources including IP addresses and Autonomous System Numbers. Each RIR consists of the Internet community in its region.
Regional Internet Registries (RIRs).
RIR74s are not-for-profit international organizations that deals with the allocation of Internet Protocol (IP) address space (IPv4 and IPv6) and the Autonomous System numbers within a geographical region There are 5 RIRs representing the different regions: RIPE NCC: Europe; Middle East ARIN: North America, Canada, US and a portion of the Caribbean APNIC: Asia and Pacific Rim AfrinNIC : Africa and LACNIC : Latin America, and parts of Caribbean The IANA allocates IP addresses to each individual RIR upon request. Then, each individual RIR is responsible for the allocation of addresses towards Internet Service Providers (ISPs), educational institutions, companies, government bodies and other such institutions and national Internet registries (NIRs)
The Internet Assigned Numbers Authority (IANA)
The IANA75 manages the allocation of global IP addresses, root zone management related to DNS (Domain Name System) and other Internet Protocols (IPs) ICANN, based
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70 https://irtf.org/ 71 https://www.itu.int/en/about/Pages/overview.aspx 72 http://en.wikipedia.org/wiki/Internet_Research_Steering_Group 73 http://www.nro.net/about-the-nro/nro-faq 74 http://icannwiki.com/index.php/RIR 75 http://icannwiki.com/index.php/IANA
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on the Memorandum of Understanding (MoU), runs IANA. The Internet Corporation for Assigned Names and Numbers (ICANN)
ICANN76 is responsible for managing the core Internet infrastructure of the internet comprising of IP addresses, domain names, and root servers. ICANN however does not have direct authority over governance issues such as cyber security, content policy, copyright protection, protection of privacy, maintenance of cultural diversity, or bridging the digital divide. ICANN is a non-profit corporation registered in California. Its functional authority rested on its MoU with the US Department of Commerce, initially signed in 1998, and extended twice. As of 1 October 2009, the formal basis for ICANN‘s function is the Affirmation of Commitments signed by ICANN and the US Department of Commerce. This document paves the way for ICANN as an independent institution. ICANN has the following Supporting Organizations and Advisory Committees: Address Supporting Organization (ASO) At-Large Advisory Committee (ALAC) The At-Large Structures are divided into five Regional At-Large Organizations Country Code Domain Name Supporting Organization (ccNSO) Generic Names Supporting Organization (GNSO) The various Stakeholder Groups/Constituencies are: Non-Commercial Users Stakeholder Group, Commercial Stakeholder Group, Commercial and Business Users Constituency, Intellectual Property Interests Constituency, Internet Service and Connection Providers Constituency, Registrar Stakeholder Group, Registry Stakeholder Group Governmental Advisory Committee (GAC) Root Server System Advisory Committee (RSSAC) Security and Stability Advisory Committee (SSAC)
The Internet Society (ISOC) ISOC77 is an active global network organization working for long term coordination of the internet development. There are various organisations associated with ISOC. It works under 3 main categories, namely: Standards: Other than supporting the 4 standards setting bodies (IETF, IAB, IESG, IRTF), ISOC also seeks to
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76 http://www.icann.org/, http://icannwiki.com , An introduction to Internet Governance, By Jovan Kurbalija, Diplo Foundation 77 http://en.wikipedia.org/wiki/Internet_Society and http://www.internetsociety.org/what-we-do
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promote the understanding and appreciation of the Internet model of open, transparent processes and consensus-based decision making. Public Policy: Working together with governments, national and international organizations, civil society, private sector and other parties, ISOC promotes policies about the Internet that conform to its core values. Education: Delivering training and arranging for conferences, supporting local and regional internet organisations, preparing white papers on issues, funding internet experts in developing nations etc.
Internet Governance Forum (IGF)
IGF78 is a multi-stakeholder forum for policy dialogue on issues of internet governance. It brings together all stakeholders in the internet governance debate -governments, the private sector or civil society, including the technical and academic community, on an equal basis and through an open and inclusive process. IGF was established in July 2006 by the United Nations. The mandate for the IGF is contained in the 2005 WSIS Tunis Agenda and was initially set up for a period of 5 years. In 2010, the United Nations General Assembly passed a resolution to continue the IGF for a further five years (2011-2015). Multistakeholder Advisory Group (MAG79) is the advisory group of IGF. The Secretariat80, based in the United Nations Office in Geneva, assists and coordinates the work of the Multistakeholder Advisory Group (MAG) and also hosts fellowships.
World Intellectual Property Organisation (WIPO)
WIPO81 is the global forum for intellectual property services, policy, information and cooperation.
World Trade Organization (WTO)
WTO 82provides the framework for general market rules. It responsible for IPR and is based on the TRIPS.
World Wide Web Council (W3C)
The W3C83 is an international community for development of web standards.
Milestones in the IANA transition
The various milestones to the IANA transition starting with the NTIA announcement and the
status till date has been chronologically shared below for easy reference.
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78 http://en.wikipedia.org/wiki/Internet_Governance_Forum 79 http://www.intgovforum.org/cms/magabout 80 http://en.wikipedia.org/wiki/Internet_Governance_Forum 81 http://www.wipo.int/about-wipo/en/index.html 82 http://www.wipo.int/about-wipo/en/index.html 83 http://www.w3.org/Consortium/mission
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Dates Milestones Remarks
March, 14th , 2014
NTIA announces84 US government‘s
intent to shift key Internet domain
name functions to the global
multistakeholder community, when the
existing IANA contact expires in
September 30, 2015.
ICANN assigned the task of assembling global stakeholders to develop a proposal, based on the parameters laid down by NTIA.
March 23rd-27th, 2014
49th ICANN meeting held in Singapore
discusses85 the IANA transition,
accountability of ICANN, issues
relating to new gTLDs such as .wine
and .vin, etc. Seeks community views
on principles and mechanism for the
transition of NTIA stewardship of the
IANA functions.
Feedbacks received include, setting up
a steering group of volunteers for the
process and to ensure a mechanism to
ensure transparency and accountability,
testing the proposed models and
establishing clear phases of activities.
April 8th, 2014
Based on the inputs received at
Singapore, ICANN prepares a draft
proposal86 on the principles and
mechanisms and the process to develop
a proposal to Transition NTIA's
Stewardship of the IANA Functions.
Inputs sought from the community on
the draft proposal.
April 23rd -24th, 2014
The Brazilian Internet Steering committee and 1net forum organize the NETmundial87 or The Global Multistakeholder Meeting on the Future of Internet Governance at Sao
Issues such as, mass surveillance, multistakeholderism, status of WSIS agreement of 2005, net neutrality, intellectual property etc. were debated. Few players such as China abstained,
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84 NTIA Announces Intent to Transition Key Internet Domain Name Functions, March 14th, 2014, Link: http://www.ntia.doc.gov/press-release/2014/ntia-announces-intent-transition-key-internet-domain-name-functions 85 https://www.icann.org/resources/pages/draft-proposal-2014-04-08-en 86 Call for Public Input: Draft Proposal Based on Initial Community Feedback, of the Principles and Mechanisms and the Process to Develop a Proposal to Transition NTIA's Stewardship of the IANA Functions, 8th April 2014-8th May 2014, https://www.icann.org/resources/pages/draft-proposal-2014-04-08-en 87 http://netmundial.br/about/
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Paulo.
while India, Russia and Cuba opposed the statement. There was mixed response from civil society while most major Internet companies welcomed the affirmation of the multistakeholder model.
May 6th -27th June, 2014
ICANN publishes a proposed process
on Enhancing ICANN Accountability
for community feedback.88
This document included comments received during the session held at the Singapore meeting, on enhancing ICANN accountability
June 6th, 2014
Based on the community feedback received at the call for initial inputs for the transition process, ICANN publishes the final process to develop the proposal for IANA transition 89
The proposal calls for formation of coordination group having 27 seats for community representatives and 2 seats for liaisons.
June 22nd – 26th, 2014
50th ICANN meeting held in London discusses need to improve ICANN‘s accountability.90
Discussion of ICANN‘s accountability with reference to the IANA transition.
July 3rd, 2014 Formation of the ICG91
ICG to have 27 individuals representing communities such as ASO, gTLD registries, IAB, ICC, IETF, ISOC, GNSO, NRO, RSSAC, SSAC, who would be responsible for preparing the transitional proposal.
August 14th, 2014
Announcement of ICANN Accountability WG and two community groups on Accountability and Governance. 92
The two community groups announced on Accountability and governance are, ICANN Accountability & Governance Cross Community Group; and ICANN Accountability & Governance Coordination Group.
August 19th, 2014
The Accountability & Governance Accountability & Governance Public Experts Group (PEG) members announced.93 The PEG group to be responsible for the selection of Advisors on the coordination group
The PEG members include, Brian Cute, representing the registry community; Jeanette Hofmann representing the academic community, Ambassador Janis Karklins representing MAG and Lawrence E. Strickling representing NTIA.
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88 https://www.icann.org/resources/pages/enhancing-accountability-2014-05-06-en 89 https://www.icann.org/news/announcement-2014-06-06-en 90 https://www.icann.org/news/announcement-2014-06-23-en 91 https://www.icann.org/news/announcement-2014-07-03-en 92 https://www.icann.org/resources/pages/process-next-steps-2014-08-14-en 93 https://www.icann.org/news/announcement-2014-08-19-en
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August 27th, 2014
The charter for ICG announced. 94 The IANA stewardship for transition
process and enhancing accountability
of ICANN to go hand in hand. The ICG
to solicit separate proposals from the
names, numbers and protocol
communities, assess the proposals,
invite comments on them and then
develop the final transition proposal,
based on broad consensus, which will
then be submitted to NTIA.
August 28th, 2014
Launch of NETmundial Initiative
(NMI)95 During the World Economic
Forum (WEF) Geneva.
September 3rd, 2014
ICG issues a RFP from the
"operational communities" on the
IANA transition.96
IANA operational communities are
those with direct operational or service
relationships with the IANA functions
operator, in connection with names,
numbers, or protocol parameters.
September 6th, 2014
ICANN announces97 a public comment
period for Enhancing ICANN
Accountability and Governance
Process.
Response to community members
seeking more time to respond
September 9th, 2014
ICG issues Request for Transition
Proposals.98
Suggested Transition Process timelines
sought from interested communities.
September 18th, 2014
ICG announces finalized Guidelines
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94 https://www.icann.org/news/announcement-2014-08-27-en 95 http://www.weforum.org/news/new-initiative-internet-governance-live-event?news=page 96 https://www.icann.org/news/announcement-3-2014-09-03-en and https://www.icann.org/news/announcement-2014-09-05-en 97 https://www.icann.org/news/announcement-08-2014-09-05-en 98 https://www.icann.org/news/announcement-2014-09-09-en
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for Decision Making.99
October 10th, 2014
Revised document on enhancing
ICANN accountability - Process and
Next Steps suggests creating CCWG.100
CCWG will have two work steams: one
focused on accountability; and the
second, on the broader accountability
issues the community would like to
bring to the forefront. PEG assigned
the responsibility of selecting 7
advisors to the CCWG.
October 12th -16th, 2014
51st ICANN meeting at Los Angeles, discusses IANA transition and Accountability of ICANN.101
The U.S. Secretary of Commerce Penny Pritzker reemphasizes the U.S. government‘s preference for non government and only multistakeholder mechanism where ICANN and IANA could be accountable, post NTIA transition.
November 5th, 2014
Proposed charter for enhancing ICANN
Accountability recommends CCWG to
organize its activities in two work
streams.102
December1st, 2014
CWG launches draft transition proposal on naming related functions for consultation and public comments.103
The draft proposal states, that there is no reason to transition the naming functions outside ICANN post the IANA stewardship transition. It suggests separation of ICANN role as a policy body from the IANA Functions Operator and that the ICANN accountability mechanisms and other improvements should be in place before the transition. The CWG transition proposal at the high level seeks to create four structures (contract Co., Multistakeholder Review Team, Customer Standing Committee, Independent Appeals Panel) to replace
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99 https://www.icann.org/news/announcement-2-2014-09-18-en 100 https://www.icann.org/news/announcement-2-2014-10-10-en 101 https://www.icann.org/news/announcement-2-2014-10-13-en 102 https://www.icann.org/news/announcement-2014-11-05-en 103 https://www.icann.org/news/announcement-2-2014-12-01-en
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the NTIA oversight. December 23rd, 2014
NETmundial Initiative (NMI) announces the formation of its inaugural coordination council.
The council to have 25 seats (20 seats divided amongst 4 sectors and 5 geographies, 3 seats for the organizing members and 2 seats left for IGF and technical community).104 NMI would remain an iterative process which would evolve through the broad-based involvement of stakeholders from across the world.
January 6th, 2015
IANA PLAN on behalf of the protocol
community submits draft response to
ICG on the IANA protocol parameters
registries.105
They propose continuing with the same
organisations or structures post the
stewardship change of NTIA with
changes necessary due to absence of
NTIA contract.
January 7th, 2015
ICG announces its transition proposal
Assembly and Finalization Process.106
This includes information regarding the
ICANN Board's role in conveying the
final transition proposal to NTIA.
January 9th, 2015
CCWG publishes a set of high level
statements for helping individuals or
community working on proposals
pertaining to the NTIA IANA
Functions' Stewardship Transition
Process.107
The statement released after accepting
the interdependency between the IANA
Stewardship Transition and Enhancing
ICANN Accountability Processes.
January 15th , 2015
The CRISP team of the Internet
Number Community releases its
proposal to ICG.108
They propose ICANN continue as the
IANA functions operator for the
numbering services post signing a new
agreement with the five RIRs and be
referred as the IANA Numbering
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104https://www.netmundial.org/blog/secretariat/netmundial-initiative-announces-formation-its-inaugural-coordination-council-and 105 http://datatracker.ietf.org/doc/draft-ietf-ianaplan-icg-response/?include_text=1 106 https://www.icann.org/news/announcement-2-2015-01-07-en 107 https://www.icann.org/news/announcement-2-2015-01-09-en 108 https://www.nro.net/wp-content/uploads/ICG-RFP-Number-Resource-Proposal.pdf
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services operator.
IPR related to the IANA services to
remain with the community.
February 6th, 2015
CWG stewardship group suggests two
types of transition models at ICANN
52.109
The models discussed were ―External
to ICANN‖ models and the ―Internal to
ICANN‖ models.
February 12th, 2015
ICANN Board clarifies NTIA is expecting
a ―coordinated proposal.‖110 ICG proposal to take into consideration the
accountability mechanisms proposed by
CCWG. ICANN to submit the same to
NTIA without any modifications but with
accompanying communication of
comments.
____________________________________
109 Cross Community Working Group (CWG) To Develop An IANA Stewardship Proposal On Naming Related Functions Discussion Document for ICANN52 Singapore February 2015, https://community.icann.org/download/attachments/49351404/CWG-SingaporeDiscussionDocument-Final.pdf?version=1&modificationDate=1422998880000&api=v2 110 ICANN 52 Board Statement on ICANN Sending IANA Stewardship Transition and Enhancing ICANN Accountability Proposals to NTIA, 12th February, 2015, https://www.icann.org/news/announcement-3-2015-02-12-en
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NTIA Announces Intent to Transition Key Internet Domain
Name Functions111
March 14, 2014 News Media Contact:
NTIA, Office of Public Affairs, (202) 482-7002, [email protected] WASHINGTON – To support and enhance the multistakeholder model of Internet policymaking and governance, the U.S. Commerce Department‘s National Telecommunications and Information Administration (NTIA) today announces its intent to transition key Internet domain name functions to the global multistakeholder community. As the first step, NTIA is asking the Internet Corporation for Assigned Names and Numbers (ICANN) to convene global stakeholders to develop a proposal to transition the current role played by NTIA in the coordination of the Internet‘s domain name system (DNS).
NTIA‘s responsibility includes the procedural role of administering changes to the authoritative root zone file – the database containing the lists of names and addresses of all top-level domains – as well as serving as the historic steward of the DNS. NTIA currently contracts with ICANN to carry out the Internet Assigned Numbers Authority (IANA) functions and has a Cooperative Agreement with Verisign under which it performs related root zone management functions. Transitioning NTIA out of its role marks the final phase of the privatization of the DNS as outlined by the U.S. Government in 1997.
―The timing is right to start the transition process,‖ said Assistant Secretary of Commerce for Communications and Information Lawrence E. Strickling. ―We look forward to ICANN convening stakeholders across the global Internet community to craft an appropriate transition plan.‖
ICANN is uniquely positioned, as both the current IANA functions contractor and the global coordinator for the DNS, as the appropriate party to convene the multistakeholder process to develop the transition plan. NTIA has informed ICANN that it expects that in the development of the proposal, ICANN will work collaboratively with the directly affected parties, including the Internet Engineering Task Force (IETF), the Internet Architecture Board (IAB), the Internet Society (ISOC), the Regional Internet Registries (RIRs), top level domain name operators, VeriSign, and other interested global stakeholders.
NTIA has communicated to ICANN that the transition proposal must have broad community support and address the following four principles:
• Support and enhance the multistakeholder model; ____________________________________
111 http://www.ntia.doc.gov/press-release/2014/ntia-announces-intent-transition-key-internet-domain-name-functions
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• Maintain the security, stability, and resiliency of the Internet DNS; • Meet the needs and expectation of the global customers and partners of the IANA
services; and, • Maintain the openness of the Internet.
Consistent with the clear policy expressed in bipartisan resolutions of the U.S. Senate and House of Representatives (S.Con.Res.50 and H.Con.Res.127), which affirmed the United States support for the multistakeholder model of Internet governance, NTIA will not accept a proposal that replaces the NTIA role with a government-led or an inter-governmental organization solution.
From the inception of ICANN, the U.S. Government and Internet stakeholders envisioned that the U.S. role in the IANA functions would be temporary. The Commerce Department‘s June 10, 1998 Statement of Policy stated that the U.S. Government ―is committed to a transition that will allow the private sector to take leadership for DNS management.‖ ICANN as an organization has matured and taken steps in recent years to improve its accountability and transparency and its technical competence. At the same time, international support continues to grow for the multistakeholder model of Internet governance as evidenced by the continued success of the Internet Governance Forum and the resilient stewardship of the various Internet institutions.
While stakeholders work through the ICANN-convened process to develop a transition proposal, NTIA‘s current role will remain unchanged. The current IANA functions contract expires September 30, 2015.
For further information see: IANA Functions and Related Root Zone Management
Transition Questions and Answers
About NTIA
NTIA is the Executive Branch agency that advises the President on telecommunications and information policy issues. NTIA‘s programs and policymaking focus largely on expanding broadband Internet access and adoption in America, expanding the use of spectrum by all users, and ensuring that the Internet remains an engine for continued innovation and economic growth. To find out more about NTIA, visit www.ntia.doc.gov.
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Members of IANA Stewardship Transition Coordination Group
(ICG) ICG comprises of 30 individuals representing 13 communities, and includes direct and indirect stakeholders who have been selected by their respective communities. The current members are: Community Name
At-Large Advisory Committee (ALAC)
Mohamed El Bashir
Vice Chair
Jean-Jacques Subrenat
Address Supporting Organization (ASO)
Hartmut Glaser
Country Code Names Supporting Organization (ccNSO)
Dr. Xiaodong Lee
Mrs. Mary Nma Uduma
Keith Davidson
Martin Boyle
Governmental Advisory Committee (GAC)
Manal Ismail
Thomas Schneider
Kavouss Arasteh
Michael Niebel
Jandyr Ferreira dos Santos
Generic Names Supporting Organization (GNSO)
Wolf-Ulrich Knoben
Milton Mueller
James Bladel
Generic Top-Level Domain Registries (gTLD Registries)
Keith Drazek
Jon Nevett
International Chamber of Commerce, Business Action to Support the Information
Joseph Alhadeff
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Society (ICC/BASIS) Internet Architecture Board (IAB)
Russ Housley
Lynn St Amour
Internet Engineering Task Force (IETF)
Jari Arkko
Alissa Cooper
Chair
Internet Society (ISOC)
Narelle Clark
Demi Getschko
Number Resource Organization (NRO)
Alan Barrett
Paul Wilson
Root Server System Advisory Committee (RSSAC
Daniel Karrenberg
Lars-Johan Liman
Security and Stability Advisory Committee (SSAC)
Patrik Fältström
Vice Chair
Russ Mundy
ICANN Board Liaison
Kuo-Wei Wu
IANA Staff Liaison Expert
Elise Gerich
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QUESTIONNAIRE
Background:
Two bodies play the central role in allocation of critical internet resources such as domain
names and IP numbers.
Internet Corporation for Assigned Names and Numbers (ICANN), a non-profit
company, under contract to report to the US government agency NTIA, is the global
policy maker for the domain name system (DNS).
Internet Assigned Numbers Authority (IANA), an agency of ICANN, which
implements policy by managing registries, root zone changes, country level domains
(ccTLDs)
In addition, VeriSign, a private company, as the Root Zone Maintainer implements changes
in the root zone file that are approved by NTIA, editing the root zone data, cryptographically
signing it (DNSSEC) and distributing the resulting content to the root server operators112
In March 2014, NTIA announced it plans to transfer the stewardship of IANA functions to a
non profit, non governmental body formed by the multistakeholder process113.
The IANA Stewardship Transition coordinating group (ICG) which was given responsibility
for preparing the transition proposals sought recommendations from the "operational
communities" of IANA, to consult within their communities and come up with a transition
proposal. A Cross Working group (CWG) was set up to develop the IANA Stewardship
Transition Proposal on Naming Related Functions.
The two operational communities, viz. protocol and number communities, have submitted
their final proposal to ICG, while CWG is yet to submit their final proposal, but its draft
proposal is still under discussion.
a. In its draft proposal for naming related functions, CWG recommends that
ICANN continue managing naming functions post the IANA stewardship
____________________________________
112 Verisign Cooperative Agreement, http://www.ntia.doc.gov/page/verisign-cooperative-agreement 113 NTIA Announces Intent to Transition Key Internet Domain Name Functions, March 14th, 2014, http://www.ntia.doc.gov/press-release/2014/ntia-announces-intent-transition-key-internet-domain-name-functions
Indian Perspective on IANA Stewardship Transition
CCAOI Confidential Report, 21st March 2015 Page 69
transition. They also propose the separation of ICANN as a policy body from
the IANA Functions Operator and that the ICANN accountability mechanisms
and other improvements should be in place before the transition. The proposal
recommends replacement of NTIA oversight by creating four structures -
Contract Co., Multistakeholder Review Team (MRT), Customer Standing
Committee (CSC), Independent Appeals Panel (IAP)114
b. IETF in its proposal115 to ICG on the IANA protocol parameters registries,
suggest continuing with the same organisations/or structures post the
stewardship change of NTIA. However, in absence of the NTIA contract, new
arrangements may be needed to ensure the IETF community's expectations
are met.
c. The CRISP team of the Internet Number Community, in their proposal ICG,
suggest116 that ICANN could continue as the IANA functions operator for the
numbering services post signing a new agreement with the five RIRs and be
referred as the IANA Numbering services operator. Any IPR related to the
IANA services would remain with the community. CRISP team suggests
establishing a service level agreement with IANA numbering services
operator. It also proposes setting up a review committee with representatives
from all RIRs to appraise the NRO EC on the IANA functions operator‘s
performance and meeting of identified service levels
ICANN has proposed117 to continue performing the IANA functions and make
necessary improvements post internal reviews. The proposal includes ICANN
coordinating the Assignment of Technical Protocol Parameters, managing the
Administrative Functions Associated with Root Management, allocating IP address
blocks and refining policies during the course of the contract.
____________________________________
114 Cross Community Working Group (CWG) on Naming Related Functions Draft Transition Proposal, Refer Summary of the transition proposal, 1st December, 2014, https://www.icann.org/public-comments/cwg-naming-transition-2014-12-01-en 115 Draft Response to the Internet Coordination Group Request for Proposals on the IANA protocol parameters registries, 7 th January, 2014, http://datatracker.ietf.org/doc/draft-ietf-ianaplan-icg-response/?include_text=1 116 Response to the IANA Stewardship Transition Coordination Group Request for Proposals on the IANA from the Internet Number Community, Chap III Proposed Post-Transition Oversight and Accountability, 15th January, 2015, https://www.nro.net/wp-content/uploads/ICG-RFP-Number-Resource-Proposal.pdf 117 Proposal to the U.S. Government to Perform the IANA Function, http://archive.icann.org/en/general/iana-proposal-02feb00.htm
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CCAOI Confidential Report, 21st March 2015 Page 70
In addition, several interest groups and stakeholders have offered several other proposals and
approaches for the IANA transition. Some of the others are outlined below:
Internet Governance Project118 suggests creating a new entity called DNS Authority
(DNSA) to manage the IANA functions related to the DNS root zone and associated
databases, while the IANA functions related to protocol parameters would be moved
to the IETF and the IP address-related functions would be retained by ICANN.
Just Net Coalition (JNC) suggests119 dividing the IANA functions such that: IETF
secretariat manages the protocol parameters; NRO manages the IP addresses; a new
entity manages the root zone file management; ICANN manages the gTLDs while
ICANN or new entity manages the ccTLDs.
Association for Proper Internet Governance120 supports a proposal of the International
Ad Hoc Committee (IAHC) (a bottom up multistakeholder group which ISOC and
others sponsored for discussions) for a Memorandum of Understanding (MoU) that
would be open for signature by any individual, state, business house, non-profit
organization, etc., who adhered to its basic principles. The MoU provided for the
creation of a legal structure, in the form of a non-profit Swiss association, and
mechanisms whereby the signatories of the MoU could make decisions and
recommendations.
Request for comments and feedback
We request your views on few of the questions shared below as that would help us to raise
issues and concerns of stakeholders like you.
1. Which of the following options that have been proposed for the IANA transition does
India support or does it have its own proposal?
2. Does India share concerns that current internet governance regime and processes need
significant change?
____________________________________
118 Roadmap for globalizing IANA: Four principles and a proposal for reform, By Milton L Mueller, http://content.netmundial.br/contribution/roadmap-for-globalizing-iana-four-principles-and-a-proposal-for-reform-a-submission-to-the-global-multistakeholder-meeting-on-the-future-of-internet-governance/96 119 Just Net Coalition: Comments on the IANA transition and ICANN accountability [Revised] (July 2014) http://justnetcoalition.org/statement/comments-iana-transition-and-icann-accountability-revised-july-2014 120 Roadmaps for further evolution of Internet governance, By: Richard Hill, http://content.netmundial.br/contribution/roadmaps-for-further-evolution-of-internet-governance/65
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CCAOI Confidential Report, 21st March 2015 Page 71
3. Does India support incremental change or overhaul?
4. Is the role and authority of ICANN as a global policy maker for the DNS121 a concern
for India? Are their alternatives for India?
5. Does India have concerns with the policy oversight of NTIA of the IANA Functions,
such as approving any changes, additions or deletions from the root zone file?
6. Does India have concerns with ICANNs role in its oversight of IANA‘s operations122?
7. What are India‘s concerns related to:
• gTLD process
• ccTLD process
• Jurisdiction
• Human Rights
• Security
• Freedom over internet
8. Does India support current arrangements where a private company (Verisign) is the
Root Zone Maintainer?
9. With reference to the guidelines laid out by NTIA for the transition, is India
concerned with:
• Role of Governments
• Decision making process
• Role of ICANN in the transition
10. Should the ICANN Accountability and the IANA globalization process be linked or
delinked and to what extent?
11. What is the kind of role, if any, should Indian or any other government play in
oversight over IANA?
____________________________________
121 http://icannwiki.com/ICANN , Section: Memorandum of Understanding 122 https://www.icann.org/en/system/files/files/sac-067-en.pdf
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CCAOI Confidential Report, 21st March 2015 Page 72
Organizations or Individuals who were contacted for this
research
Industry Bodies
Associated Chambers of Commerce and Industry of India (ASSOCHAM) Confederation of India Industry (CII) Cellular Operators Association of India (COAI) Data Security Council of India (DSCI) Federation of Indian Chambers of Commerce and Industry (FICCI) Internet and Mobile Association of India (IAMAI) Internet Service Providers Association of India (ISPAI)
Industry
Facebook India Google India gTLD applicants from India ICANN
Civil Society
Centre for Communication Governance (CCG) Centre for Internet Society – India (CIS India) Free Software Movement of India (FSMI) IT for Change (ITFC) Internet Democracy All ISOC Chapters of India
Government
Department of Electronics and Information Technology (DeitY) Department of Telecommunications (DOT) Ministry of External Affairs (MEA) National Internet Exchange of India (NIXI)
Legal & Consulting Firms
Amarchand & Mangaldas & Suresh A. Shroff & Sons Academics
Dr. Rekha Jain Prof. Vivekanandan
Others
Activists Experts Educationist
Indian Perspective on IANA Stewardship Transition
CCAOI Confidential Report, 21st March 2015 Page 73
ABOUT CCAOI
CCAOI is a not for profit body representing the ecosystem of Internet in India comprising of:
Connectivity Providers: ISP, BWA providers and Public Internet Access Providers
(PIA's) comprising of 1,80,000 Cybercafés/75,000 CSCs
Content Providers: eGovernance, eCommerce, eEducation, eMedicine
Cyber Security: Safe Internet and Safe Cafe/CSCs, &
The association was set up with the objective of promoting internet to the common masses
across India. CCAOI is responsible for bringing to the forefront and voicing the woes of the
entrepreneurs at the required forums on their behalf thereby, protecting their interest and
helping them establish and sustain a world class infrastructure, which in turn would facilitate
affordable internet services to the "Aam Aadmi‖.
To achieve this, CCAOI interacts and works closely with the Government, the Regulators,
Policy Makers and major Industry Chambers.
Everything that CCAOI has done or achieved, since we began operations, stems from our
Purpose and Vision. All services provided to our members Free of Cost. The key aspect of
our vision is that CCAOI be an enabler for the India Model and Catalyst of the Internet for
positive change in India - a responsibility that we continue to carry.
The endeavour of CCAOI has always been to bring together all these stakeholders and create
an environment and a Win–Win situation for all stakeholders, so that the internet ecosystem
flourishes.
CCAOI‘s various initiatives on both Rural & Pan India perspective
The association has launched various initiatives with the objective to build the ecosystem and
help take internet to people in the lowest wrung of the pyramid, touching their lives, which
would help intensely for our vision of ―Digital India‖.
Community Services of CCAOI
The CCAOI platform is also facilitating services for the community like Free Legal
Support, supporting CDAC in providing free vernacular software in 22 Indian languages,
Indian Perspective on IANA Stewardship Transition
CCAOI Confidential Report, 21st March 2015 Page 74
thereby promoting internet in the language of choice of the common man. We have also
released the Best Practices Guide for Cybercafés/CSC’s in various Indian languages.
For the development of the community, the association has been regularly submitting white
papers on internet and broadband penetration to TRAI, DOT, Railtel, USOF, on Green
telecom to TRAI, on cybercafés to the Government, and has been successful to
convince RBI to appoint CSC‘s and Cybercafés as BC. TRAI too in their recommendation
paper on National Broadband Plan has recommended digital literacy and promoting internet
through cybercafés and CSC‘s. CCAOI had also submitted a notice of Intent to to create a
new constituency for Public Internet Access Providers/Cybercafés worldwide
(http://gnso.icann.org/en/improvements/newco-process-en.htm) to ICANN (Internet
Corporation for Assigned Names and Numbers).
CCAOI Research Papers CCAOI has been conducting studies in issues pertaining to Privacy, security, online protection and
Internet Governance.
CCAOI e-Learning Services
CCAOI, a comprehensive e-Learning Solution Provider, brings world-class technology, tools
and content services to its customers. We are currently executing and delivering eLearning
for Indian consumers through CCAOI affiliated Public Internet Access Points (Cybercafés/
CSC‘s). Currently, a tie-up with Not-for-profit body is underway to ensure one lakh Indians
as Netizens vide our Internet Learning Programmes supported by Digital Literacy Course
and Office-Basics.
The association is promoting Free Internet Learning program for all in Vernacular languages.
TRAI in their National Broadband Recommendation Paper has also recognized our
Digital Learning Program and has suggested, ―the Government should involve associations
and NGOs at the grass root level in the Awareness Building Campaigns and all these
initiatives should be funded by the Government.‖Programs similar to the CCAOI Project
Gyan™, a 10- day Internet Learning Program which is offered for Free from
Cybercafés/ CSC’s and taught in the preferred language of the citizen, could be
promoted by the Government.”
We also have alliances with online-tuition companies to conduct tuitions for Mathematics and
Science for CBSE as also the State Boards. Similarly, there is an alliance in process with
Indian Perspective on IANA Stewardship Transition
CCAOI Confidential Report, 21st March 2015 Page 75
Libra, who has developed a world class spoken English product with voice recognition
technology (learning through 10 regional languages). The product runs through internet
connection and is expected to revolutionize the spoken English learning in India.
CCAOI Safe a Secure Internet Access
We have also launched along with Connect9 and Airlink a Free Surveillance System for
Cafes. Apart from being compliant to the recommendations provided by the Govt.,
towards Cyber Security & Surveillance by providing a Unique Identification (UI) to all
cyber cafe customers & secured authentication and all this FREE with negligible monthly
maintenance charges. Using this UI, any person will be able to use cyber cafes all over the
country, without having to prove his/her identity every time. This shall help Cybercafé
owners to adhere to the government norms for tracking details of every user, in an efficient &
cost effective manner.
To promote Safe and Secure Internet Access, CCAOI with the support of CERT-In had
also launched a fortnightly Security Newsletter.
Adding a Revenue Source to the Public Internet Access Points
As an association, we believe that till the time all the stakeholders of the ecosystem do not
work hand in hand, internet penetration in the country will not improve. The association is
working not only to improve the revenue opportunities of the Public Internet Access
providers in the country, thereby providing the required service to end consumers, but
through these initiatives provide opportunities to the content providers. All these initiatives
are offered Free of Cost to the members. Some of the initiatives are opportunity to
become domain name resellers, website builder etc.
CCAOI Online Value Added Services-Empowering consumers online
In addition to connecting consumers to internet, CCAOI is working with Connect9, an
eCommerce platform to provide its members with tools and channels to improve the quality
of their lives and also, provide all eServices to the citizens of the country. This spans from
Government services, the basic services as Bill Settlement including Mobile recharge,
Electricity payment, School Fees to booking Railway & Air tickets, Hotels and holidays,
Online Portfolio Management, Personal Finance, Education Courses, Job related Trainings,
Games, Gifts, Entertainment and much more.
For more details visit www.ccaoi.in
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CCAOI Confidential Report, 21st March 2015 Page 76
Dr. Mahesh Uppal
Mahesh Uppal is the Director of Com First (India) Private Ltd., a niche consultancy company based in New Delhi, India that specializes in policy, regulation, and strategy.
Mahesh Uppal was educated at St Stephens College, Delhi, Indian Institute of Technology, Kanpur, and City University, London. He was part of the research staff at Indian Institute of Science, Bangalore, Heriot-Watt University, Edinburgh, Cambridge University, Cambridge, and Sussex University at Brighton in United Kingdom.
He has advised several major national and international corporations in the telecom and IT arena, including international technology companies as well as telecom operators.
He has consulted for several international development agencies including the World Bank, International Telecommunication Union, United Nations Development Programme, Canadian International Development Agency, and International Development Research Centre. He also advised several governments on telecom policy and regulatory issues. He has also worked with several civil society organizations in India to build capacity in dealing with emerging regulatory issues.
Mahesh Uppal can be reached on [email protected] or on +919810042969
Indian Perspective on IANA Stewardship Transition
CCAOI Confidential Report, 21st March 2015 Page 77
Amrita Choudhury
Amrita serves as the Director of CCAOI. Her involvement at the grass root level for nearly a
decade with Internet penetration across the country, has given her a comprehensive
understanding of the dynamics of the Public Internet Access providers (Cybercafés and
CSC‘s), the current challenges and the opportunities this sector presents.
Her work focuses on a wide range of issue like, empowerment of the Public Internet Access
providers (Cybercafés and CSC‘s), promoting Internet awareness through Digital Literacy
and vernacular Internet, Safe surfing, Internet Governance etc.
She is an ardent advocate that the ―Aam Aadmi‖ in India can be only become empowered
with the help of Internet awareness. This, she believes can only happen when there is mass
scale internet penetration in the country and active involvement of all the stakeholders. The
mass internet penetration is only possible through the Public Internet Access providers, the
most crucial stakeholder in the Internet ecosystem of India and the entire ecosystem can only
improve when all the stakeholders work together in unison.
Besides being a student of Public Policy and Regulations, Amrita has certificates in Internet
Governance and Advanced Phased Certification on Security. She has a 6sigma black belt
certification and holds a Post Graduate degree in Management.
She can be reached at [email protected] or on +91 9899682701
CCAOI, C/o Abbot Business Centre, N52, Connaught Place, New Delhi -110001, Contact No. + 011-43589898, Website : www.ccaoi.in