Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

Контент доступен только на следующих языках

  • English

Name: Registries Stakeholder Group (RySG)
Date: 16 Nov 2022
1. Do you have any comments on the Draft IANA FY24 Operating Plan & Budget or the Draft PTI FY24 Operating Plan & Budget with regards to document structure, length, or level of detail?

- The FY24 IANA and PTI documents have largely the same structure as the FY23 documents, this helped facilitate the review process.

- Our review noted slight editorial differences in the Planning Process Overview section of the PTI OPB; these edits improve the clarity of the text, especially for readers unfamiliar with the unique structural relationship between PTI and IANA.

- In the area of budget comparisons (re: section on PTI Budget Variance) the clarity would be improved if there were quantitative comparisons with the prior year budget.  There are comparisons to FY22 actuals (top of p. 21) , but the chart at the top of p.20 lacks a set of columns that includes the FY22 (prior year) Budget and comparisons.  

- Similarly, the chart at the bottom of p. 19 (“FY24 Grant Total Including Support Functions Shared with ICANN”) would be more helpful if it included a comparison to FY23.  

- And further, the chart at the bottom of p. 21 (Budget Variance by IANA Function) lacks a comparison to the FY22 budget. 

2. ICANN uses a set of assumptions when planning and budgeting. Please review the planning assumptions used for the development of the Draft PTI FY24 Operating Plan & Budget. Do you have any comments on the FY24 Planning assumptions?

In general, the assumptions appear both reasonable and consistent with prior years.  We note that the Shared Support Functions is one of the budget areas that has the most change, both in terms of allocations and variance percentage (see chart on p. 18).  Perhaps in future budget cycles, the set of assumptions needs to expand to include these Shared Support Functions.

Related to the Community Recommendations section of the Assumptions, the PTI FY23 document includes specific mention of several examples of work that is not yet approved for implementation, content that was not included in the FY22 document.  But the list of examples in the FY24 document does not include any commentary about the likelihood of these possibilities becoming actualities during FY24 or about the budgetary/operational impact that they might have on PTI.  As stakeholders of IANA, the impact of these initiatives on IANA could influence RySG input on various initiatives.     

3. PTI operations are displayed in four focus areas: operations, operational excellence, technical services, and governance. Do you support the projects and activities that are planned for each of these areas as described in the Draft PTI FY24 Operating Plan? Please provide detailed reasoning for your answer.

In general, the RySG supports the projects and activities described in the Draft PTI FY24 Operating Plan.

However, we noted the presence of a project in Technical Services: “Significant re-evaluation and redesign of the iana.org website, including mobile accessibility”.  While we offer that iana.org does not have the most visually stunning presence on the web, we find the site to be serviceable.  Perhaps more importantly, we recognize that the “re-evaluation and redesign” would likely be both expensive and time-consuming.  The current budget document does not include calendar or cost estimates for the project.  And depending on when the work is started, it could easily stretch across fiscal years, making the true cost less obvious.  Therefore, we question both the scale and the priority of this work, relative to other projects on the docket.  If there are known areas of the site that are in need of improvement, perhaps these could be addressed without a full-site overhaul.

In Governance, we noted that “Providing support to the PTI Board” no longer appears in the list of activities.  This did appear in the FY23 document.   Given the inclusion of “PTI Board Support” on p. 18 under “direct shared costs” is it correct to assume that this function has fully moved to the ICANN org?

4. The Draft PTI FY24 Operating Plan & Budget continues to define and demonstrate how PTI will implement the Strategic Plan for Fiscal Years 2021–2024. Do you have any comments on whether the activities included in the Draft PTI FY24 Operating Plan & Budget and appropriately support the achievement of the objectives stated PTI Strategic Plan for FY 21-24?

In general, we observe that the activities included in the Draft PTI FY24 Operating Plan & Budget appropriately support the achievement of the objectives stated in the PTI Strategic Plan for FY21-24.  However, we do note that the plan does not appear to have heavy emphasis on certain areas focused on improving efficiency in delivery. 

For example:


Operational Excellence:

4.3 – Monitoring key performance indicators to ensure performance (...) remains (…) relevant and fit-for-purpose


Governance: 

5.2 – Reducing unnecessary complexity and duplication between what is in scope for IANA and ICANN

5.3 – Identifying opportunities to streamline oversight agreements and contracts 


In making this comment we seek to be clear that we appreciate the overall effectiveness of the PTI organization and we seek to allow them to retain the capacity and readiness to take on future challenges.  A key part of this is to help PTI avoid being overly burdened by process and metrics that do not truly benefit performance.

5. The Draft IANA FY24 Operating Plan and Budget includes the PTI Operating Plan and Budget and other supported activities provided by ICANN. Do you have any comments regarding the activities or projects?

NOTE:  The above text says:  “Please refer to Draft PTI FY24 Operating Plan and Budget, pages 6-7”; this appears to be a typo and should say:  “Draft IANA FY24…” (emphasis added)

In the tables on page 7,  the clarity would be improved if there were quantitative comparisons with the prior year (FY22) budget.  There are comparisons to FY22 actuals , but the charts on p.7 lack a set of columns that includes the FY22 (prior year) Budget and comparisons

In general, there is little information regarding the $600K allocation from IANA to ICANN org for “IANA support activities”.  While that amount remained constant in FY24 as compared to FY23, an area for improvement would be to provide additional detail in this area.  As a model, consider the information provided in the PTI document on p. 17-18, including the FTE table.

6. Do you have any additional observations or comments?

We would not be the first to note the oddity of ICANN having a five-year strategic planning window while PTI has a four-year cycle.  It would seem to negatively impact the long-term effectiveness of PTI’s strategic planning to have this inconsistency with respect to ICANN’s plan.  And there are likely efficiency benefits to having some coordination. 

Summary of Submission

Overall, the RySG supports the PTI FY24 Budget and Operating Plan.  The RySG recognizes and appreciates the hard work by PTI to maintain a constant headcount in the budget.  However, as described elsewhere in our submission, we note the following:

- The RySG would like to see IANA/PTI examine opportunities for operational efficiency, especially in the area of metrics;

- The FY24 plan includes a project related to a “significant re-evaluation and redesign of the iana.org website”, which is an effort that could easily involve a challenging operational transition, along with significant time and expense; therefore, the RySG would like to see this effort either better explained and/or deprioritized; and

- The biggest year-to-year variance in PTI costs are those related to direct charges for services delivered by ICANN org; therefore, the RySG would like to see greater clarity and transparency regarding these costs.