RE: [nc-str] Draft report on ALSC V 4
Phil, We have carefully reviewed the draft and forward our comments. At the outset, we are a bit surprised to see the checklist for input blank next to IPC. As you recall, we submitted very early on our comments and I have forwarded suggestions to you. The thrust of the IPC's comments on the draft ALSC report focused on whether the ALSO would be ready for prime time. The latest draft, in our view, gives that issue rather short shrift; it focuses on the number of members -- presumably paid members,though point 4 does not say so -- but that is only one criterion. As the IPC comments stated: "The IPC views the proposal to establish an At Large Supporting Organization (ALSO) as raising significant questions, particularly with respect to financial and administrative manageability. It is critical that unambiguous criteria be set up to gauge whether the ALSO is in fact ready to operate as an ICANN supporting organization, especially from these two perspectives. Criteria such as those relating to significant membership numbers, the ability to effectively keep members informed, and adequate financing for meetings and dues payments are crucial to ensuring that the ALSO can support its mission, will not be subject to capture by a small group, and will be in a position to offer substantive opinions on DNS administration." Also, we note that the ALSC report only deals with the at-large members of the Board, not with allocation of the other 2/3's. I think it is important that this misconception not be continued in the latest draft. As we indicated in our Comments which we sent to you: " We note that, to whatever extent the implementation of
the ALSC recommendations changes
the manner by which the rest of the ICANN board seats are allocated, special
care must be taken not to disenfranchise other participants in the ICANN process
or reduce their level of or access to representation within the hierarchy of the
ICANN leadership. " Accordingly, it is important for the draft report to make clear that any discussion of structural proposals found in the ALSC report are clearly and specifically directed to the ALSC's recommendations with regard to the ALSO and NOT any ancillary commentary on the structure of ICANN as a whole. We have a number of concerns with the recommendations, which in effect endorse the functional equivalent of an individual domain name holders' constituency (3 votes for ALSO reps on the Names Council, except in electing Board members) AND the ALSO itself. We note that the Names Council has just adopted a TF review report that sets out criteria for the recognition of new constituencies which have not yet been applied to any petition by a group purporting to speak for individual DN holders. The draft report of the Structure TF does not question the ALSC conclusion that individual DN holders should be the electorate for the ALSO ( a conclusion that the IP constituency, in its comments on the draft ALSC report, noted that "all domain name holders (including those in ccTLDs as well as in gTLDs) should be entitled to vote, on the basis of one at-large membership per domain name holder", without regard to whether the DN holder is or is not an individual,a fact that will be almost impossible to determine). If that conclusion is accepted, then how do the 3 ALSO voting rep's on the DNSO differ from the IDNO which has never been accepted or even measured against the criteria that the NC has adopted? As for specific comments: In the fourth box under item 2(a), the draft predicts a "high" effect of the ALSO on the DNSO consensus process. This may be a bit exagerated as the problems of overlap and duplication which the draft report identifies will also make it more difficult for the DNSO to achieve consensus. In the first box under item 2(b), while I agree that the impact of ALSO on "the ability to generate valid consensus-based policy making" may be "uncertain," it seems almost certain to complicate the process of attaining consensus in the first place. For your convenience I again attach the IPC comments and hope that some of their points can be reflected in this Structure TF report. ***********************************************************
Domain Names IPC revised DRAFT ALSC comments sjm 110901.doc
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