Comments on DNSSEC Policy and Practice:

The IFRT2's recommendation to remove specific Domain Name System Security Extensions (DNSSEC) policy details from the IANA Naming Function Contract and instead identify and point to the appropriate policy authority aligns with principles of good contract management and adaptability. Embedding technical policy details within a long-term contract can lead to the contract becoming outdated quickly as best practices and technologies evolve. By referencing an external, authoritative policy source, the contract can maintain its relevance without requiring frequent amendments for technical updates.

Question: How will the "appropriate policy authority for DNSSEC" be formally identified and documented within the IANA Naming Function Contract? Will there be a specific mechanism for ensuring that this referenced authority is widely recognized and trusted by the ICANN community?

Analysis:

Pro (Removing Specific Details): This approach offers greater agility and allows DNSSEC policies to be updated more efficiently by the relevant technical bodies without necessitating a formal contract amendment process, which can be lengthy. It promotes the use of current best practices.

Con (Removing Specific Details): There is a potential risk of ambiguity if the referenced policy authority is not clearly defined or if its decision-making processes lack transparency. Stakeholders might find it harder to ascertain the exact DNSSEC requirements by solely relying on an external reference.

Pro (Identifying Policy Authority): Clearly identifying the authoritative source enhances transparency and allows stakeholders to easily locate the applicable DNSSEC policies. It clarifies responsibilities for policy maintenance.

Con (Identifying Policy Authority): Identifying a single "appropriate" authority might be challenging given the distributed nature of internet governance and the various bodies involved in DNS security. There might be disagreements on which entity holds the ultimate authority on DNSSEC policy best practices.

Benchmarking against similar organizations that manage technical standards often reveals a preference for referencing external specifications rather than embedding detailed technical information within foundational governance documents. This allows for more flexible and expert-driven evolution of technical standards.

Comments on Transparency and Availability of Contract Amendments:

The IFRT2's finding that amendments to the IANA Naming Function Contract were not immediately obvious or available to the review team highlights a crucial aspect of transparency in any organization, especially one with a significant public interest mandate like ICANN. The recommendation to make the amended contract publicly accessible or provide a clear mapping of amendments is essential for accountability and for facilitating informed participation from the community and review bodies.

Question: What specific mechanisms will be put in place to ensure that all future amendments to the IANA Naming Function Contract are easily identifiable and accessible to the public? Will a version control system or a clearly marked consolidated version of the contract be implemented?

Analysis:

Pro (Improved Transparency): Enhanced transparency regarding contract amendments builds trust within the community and enables stakeholders to understand the current contractual obligations of the IANA Functions Operator. It also facilitates the work of future review teams.

Con (Improved Transparency): Implementing a system for tracking and displaying amendments might require some initial effort and resources. There's also a need to ensure that the system is user-friendly and that stakeholders are aware of its availability.

Pro (Mapping Amendments): Providing a clear mapping of amended lines alongside the original contract offers a straightforward way for stakeholders to understand the changes.

Con (Mapping Amendments): Maintaining an accurate and up-to-date mapping could become complex if there are frequent or extensive amendments. Accessing two separate documents (original and the map) might be less convenient than a consolidated amended version.

Many standards development organizations and multi-stakeholder initiatives prioritize clear and accessible documentation of their foundational agreements and any subsequent modifications. This ensures that all participants operate under a shared understanding of the governing rules.

Comments on Frequency of Reviews:

The IFRT2's recommendation to amend ICANN Bylaws Section 18.2(b) to measure the five-year IANA Naming Function Review period from the date the IFRT submits its Final Report to the ICANN Board of Directors, rather than when the previous IFRT was convened, addresses a practical concern about the time available to observe the impacts of prior changes. Given that periodic IFRs take 12-18 months to complete, starting a new review too soon after the previous one concludes might limit the ability to assess the effectiveness of implemented recommendations.

Question: What measures will the ICANN Board of Directors put in place to "ensure that procedural controls exist to mitigate the risk of stalled reviews" if the review period is tied to the submission of the final report?

Analysis:

Pro (Changing Review Frequency Metric): Aligning the review cycle with the submission of the final report allows for a more meaningful interval to observe the outcomes of the previous review's recommendations before the commencement of the next one. This can lead to more informed and effective reviews.

Con (Changing Review Frequency Metric): There is a potential for delays in the completion of an IFRT's work, which could inadvertently extend the review cycle beyond the intended five-year period if not managed effectively.

Pro (Current Review Frequency Metric): Measuring from the convening date provides a more predictable schedule for the reviews.

Con (Current Review Frequency Metric): As highlighted by the IFRT2, this can lead to new reviews starting before the impact of the previous recommendations can be adequately assessed.

Organizations with periodic review mechanisms often adjust their schedules based on the complexity of the issues being reviewed and the time needed for implementation and observation of changes. The IFRT2's recommendation reflects a pragmatic approach to ensure the review process remains effective.

This submission generally supports the recommendations of the Second IANA Naming Function Review Team (IFRT2) Initial Report. The recommendations regarding the removal of specific DNSSEC policy details from the IANA Naming Function Contract and the clear identification of the relevant policy authority are in line with good contract management and adaptability. The emphasis on enhancing the transparency and accessibility of contract amendments is crucial for accountability and informed stakeholder participation. Finally, the proposed change to the frequency of reviews, measuring from the submission of the final report, appears to be a sensible adjustment that will allow for a more thorough assessment of the impact of prior recommendations. It is important that ICANN clearly defines the referenced DNSSEC policy authority, establishes robust mechanisms for making contract amendments easily accessible, and implements procedural controls to prevent undue delays in the review process.