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Name: JIM Reid
Date: 22 Sep 2025
Affiliation: RTFM llp
Other Comments

The RSS-GWG report is a very welcome and long overdue first step towards governance of the Root Server System (RSS).

However it is disappointing. The report falls short in too many ways. Implementation detail has been glossed over and/or delegated to a hypothetical successor body that is expected to create a viable governance structure for the Root Server System (RSS-GS). The RSS-GWG report seems to have done little to expand on what was proposed in RSSAC037 and RSSAC038. The RSS-GWG output only makes passing references to RSSAC058, Success Criteria for the RSS Governance Structure. It does not explain how the proposed Governance Structure matches or exceeds those criteria - or if the criteria in RSSAC058 are adequate for oversight of the RSS.

In my opinion there are a number of serious defects and omissions in the RSS-GWG report:

1) RSS-GWG report does not explain how/if the proposed RSS-GS would be incorporated (or not) or where/how/if it would sit alongside other stakeholder groups at ICANN like GAC, gNSO, ASO and so on.

2) There is no indication of the expected budget for the proposed RSS-GS or how it would be funded.

3) It is not clear who the contract parties, if any, would be in the proposed RSS-GS.

4) In short, the RSS-GWG report lacks the basic elements of a business plan for the RSS-GS.

5) There is no estimated budget for the RSS-GS secretariat and no indication how it would be paid for or what sort of legal entity would be used to employ the secretariat's staff, pay for meetings, buy IT services, etc. This would presumably be paid by ICANN if the RSS-GS fitted into ICANN's governance structure. However it is not clear from the report if the RSS-GS will fill that role.

6) The creation of the proposed RSS-GS will have obvious impacts on RSSAC and RSSAC Caucus. These have not been explained. It's not clear how these bodies will interact once the RSS-GS has been established - or if they would still be needed.

7) A 27-member council is unreasonably large and is likely to be impractical. It is larger than the boards of comparable institutions: ICANN, each of the RIRs, PTI, the IETF, etc. It's larger than the cabinets of most countries!

8) The composition of this council is drawn from a narrow set of stakeholders which excludes several groups that should be represented. It is also too heavily skewed in favour of the Root Server Operators.

9) The internal elements of the proposed Governance Structure - its subcommittees and so on - are discussed in the abstract. It's not clear how they will interact with each other. These interactions have not been tested or analysed.

10) The proposed Governance Structure seems to enshrine (ossify?) the current model of serving the DNS root. It lacks the flexibility to accommodate new approaches that would improve stability and security of the RSS: for instance widespread adoption of hyper-local roots (RFC8806).


For full disclosure, I am a member of the RSS-GWG and have served for two years. I abstained when it voted on submitting its report to ICANN.

Summary of Attachment


Summary of Submission

This is a welcome first step towards root server system governance, but one which has too much left unsaid and undone. The report is unlikely to provide a strong enough foundation for governance of the root server system.