The Internet Architecture Board [IAB] appreciates the opportunity to provide feedback to ICANN on the "Functional Model for Root Server System Governance" report from the Root Server System Governance Working Group (RSS-GWG).

While the IAB welcomes and supports any effort to maintain and establish a strong, sustainable, and resilient governance model for the Root Server System, we are concerned that the report does not provide a detailed enough approach to achieve the important goals of accountability and transparency.

A well-elaborated approach to the governance of the Root Server System is fundamental to the secure and stable operation of the Internet, and it is imperative that this model be established with precision and care. We are concerned that the lack of detail means that the report does not sufficiently address critical components of accountability, practical operations, as well as balanced, transparent and timely decision-making. As a result, there is a risk that several recommendations and principles in the report might not be implementable or achievable.

We therefore believe that the report does not sufficiently address the suggestions made in RSSAC0037 and RSSAC0038. The ability to address future challenges in the governance of the root server system in a timely and transparent way is essential for the stable operation of the Internet and could otherwise reflect negatively on the whole ecosystem.

The IAB suggests that the next steps of the process should involve providing more details and a plan for implementation, with additional outreach for review, comments, and detailed feedback at each step (Initiation Phase, Establishment Phase, Governance Phase), if the Board decides to accept the report. We are ready to provide such feedback during the ongoing process and to work with ICANN, RSOs, and other relevant groups to strengthen the root server governance and operation.

Respectfully,

Internet Architecture Board