|SOME THOUGHTS ON POSSIBLE IMPROVEMENTS TO THE IANA FUNCTIONS
A response to the NTIA RCO (Docket No. 110207099-1099-01)
My name is George Papapavlou. I am currently one of Greece’s representatives in ICANN’s Governmental Advisory Committee (GAC). Nine years ago, from 2002-2004 (from the Accra until the Rome meetings), I was the representative of the European Commission in the GAC. I have thus been involved in the ICANN and IANA discussions among governments almost since the early days of ICANN. The comments that follow are my own and do not represent a position of the Greek government.
The NTIA RCO asks six specific questions, the majority of which concern the technical experts in the Internet community. One question, question no 3, is of particular interest to national governments: “Cognizant of concerns previously expressed by governments and ccTLD operators and the need to ensure the stability of and security of the DNS, are there changes that could be made to how root zone management requests for ccTLDs are processed? Please provide specific information as to why or why not. If yes, please provide specific suggestions”.
In my view experience has shown that there are two areas in which improvements can be made.
1. The political domain. There has been increasing international awareness, since the days of Jon Postel, that ccTLDs are TLDs belonging primarily to the national Internet community of the countries concerned and that national governments are the political representatives of those communities. This awareness is reflected in the 2005 GAC Principles and Guidelines for the Delegation and Administration of Country Code Top Level Domains. I am quoting two main principles: “4.1.1. Ultimate public policy authority over the relevant ccTLD rests with the relevant government or public authority; how this authority is exercised is determined by applicable law.
4.1.2. Every country or distinct economy with a government or public authority recognised in accordance with article 3.8 above should be able to ask for its appropriate country code to be represented as a ccTLD in the DNS and to designate the Registry for the ccTLD concerned”
The political argument that has been expressed by several countries concerns the fact that any changes to the root resulting from ccTLD or gTLD requests are implemented by Verisign after approval (and signature) by the US government. In the early days this situation had prompted an extensive “internationalisation” debate and some requests to transfer the IANA Functions to the UN or to the ITU. Fortunately this was averted as a result of the creation and successful functioning of ICANN. Although the US have never abused their IANA control power the international political concern, albeit symbolically, remains. At the same time there has been a gradual maturing and increase of the role of the GAC, especially as a result of the AOC process. In my view the GAC could now be given a lightweight role in the IANA Functions in a way that would alleviate concerns about exclusive US power without burdening those functions. My basic idea is that a GAC representative (other than the US representative) could countersign the root zone change requests, together with the US government-delegated official. Several options could be considered: 1.That this would apply only to ccTLD changes and the GAC signatory would come from the country of the ccTLD concerned. 2. That this would apply only to ccTLD changes and there will only be one GAC representative designated by the GAC on a rotating basis (e.g. annual). 3. That this would apply to both ccTLD and gTLD changes and there will only be one GAC representative. Option 2 is the simplest, option 3 is more complete, option 1 would best reflect countries’ sovereignty claim for their ccTLDs. The fact that there will also be the US official’s countersignature should alleviate domestic US political concerns.
This idea has not yet been discussed within the GAC or within the EU institutions.
2. The second is the area of IDNs. Greece has had a long and traumatic experience in the process of having its selected IDN, .ελ, introduced into the root. At first, and after the request had been expressed to IANA from the Greek .gr ccTLD Registry, with the signed support of the Greek government, IANA questioned the support of the Greek “Internet community” and the linguistic pertinence of the chosen Greek alphabet letters. After these obstacles were overcome through additional - but completely unnecessary - documents and certificates from Greece, some unknown but omnipotent “committee of experts” decided that the chosen Greek letters were “confusingly similar” with other, Latin alphabet letters and rejected Greece’s request! ICANN’s CEO told me he was unable to interfere with this verdict, which was decisive and could not be appealed against. Fortunately word of this story came to the ears of some ccTLD managers who were immediately able to recognise the sheer inadequacy of that verdict and have set up a working group to reconsider the evaluation process for IDNs and Greece’s IDN request.
IANA has no right to question languages or local Internet community support. Governments are in the position of expressing their national Internet communities. The “confusing similarity” criterion should not be the result of some technical algorithm but of simple common sense. In the Greek example: The capital letters version of .ελ (ΕΛ) was considered to be confusingly similar to the Latin alphabet letters EA.. The possibility of such confusion for a Greek language speaker, who uses exclusively Greek alphabet to type the whole domain name or address, to then switch into capital letters and type EA in Latin alphabet is close to zero. After all, there is currently no .ea or .EA ccTLD. In my view, any IDN request which is technically complete, tabled by a body with obvious TLD expertise and has the support of the government concerned should be accepted by IANA. Where there is a need for technical judgement ccTLD-designated delegates should be part of any IANA technical committee, to ensure that decisions are in conformity not only with technical but also with common sense criteria regarding the alphabet concerned.