Comments from the Internet Infrastructure Coalition (i2Coalition) On Next Steps to Improve the Effectiveness of ICANN’s Multistakeholder Model The Internet Infrastructure Coalition (i2Coalition) appreciates the opportunity to comment on ICANN's Next Steps to Improve the Effectiveness of ICANN’s Multistakeholder Model report, filed 20 August, 2019. The i2Coalition’s diverse membership represents both large and small Internet infrastructure providers such as web hosting companies, software services providers, data centers, registrars and registries. The i2Coalition has several key goals within ICANN, but chief among them is continuing to build a voice for underrepresented parts of the Internet ecosystem – in particular web hosts, data centers and cloud infrastructure providers – and ensuring that accountability and transparency are paramount. The i2Coalition brings unique representation to ICANN as it is made up of companies representing the broad ecosystem of Internet infrastructure companies. General Response Comments We appreciate the extensive work done to date on this subject. i2Coalition agrees that duplication of work, inconsistent prioritization, and siloed problem-solving are significant issues within the ICANN community, and we welcome a dialogue to find solutions to those issues. For each issue area, we have provided encouraging and guiding notes to Facilitator Observations throughout, as ICANN seeks to synthesize Facilitator work and draw conclusions and actions from this work. Issue Response Comments Issue 1 - Prioritization of work Comments: We have no specific comments at this time on this matter. Prioritization: • Is fully addressed by solution being developed in another workstream. Issue 2 - Precision in Scoping Work Comments: With respect to the scope of the policy development process we have no specific comments at this time on this matter, but continue to support the GNSO’s PDP 3.0 development process. Another scope-related issue pertains to the various review processes which have grown both in number and in scope. While the bylaws establish procedural guidelines for Specific Reviews the scope of the review is not clearly established and the procedures are less clearly fixed than the GNSO PDP. We strongly believe that the PDP remains the vehicle by which all binding policies governing generic names should be developed. The recent tendency to advance policy changes through Specific Reviews, rather than the PDP undermines effective scoping, prioritization, and efficiency. Because reviews are not necessarily held to the same procedural checks that are built into the PDP they may end up prioritizing changes that, at best, do not reflect the highest-priority areas of change for the GNSO or, at worst, actually run counter to the community’s interests. Reviews should be a chance to take stock of particular aspects of ICANN and identify what is working and what is not. To the extent review teams identify necessary changes as part of that review, they should be advanced using the GNSO PDP which has greater checks and balances. Requiring all policy change to pass through the PDP will also force the community to prioritize what matters most in selecting what topics should be advanced as issue reports and PDPs rather than allowing some topics to short-circuit policy development through the review process. More generally, ICANN’s bylaws refer to “coordinating the development and implementation of policies for which uniform or coordinated resolution is reasonably necessary to facilitate the openness, interoperability, resilience, security and/or stability of the DNS…” As part of both initiating policy development work and finalizing recommendations, the community should actively consider whether policies are reasonable and required to serve one or more of these objectives. We believe that a more conscientious check on whether policy development is reasonably necessary could narrow the overall scope of work being pursued. In addition to limiting police development to the areas were it is required, we believe that careful attention to the need to make policies flexible and adaptable would minimize the need to redo work to adjust to changes in technology or legal contexts. Prioritization: • Review scoping must be addressed in the Evolving ICANN’s MSM Work Plan. Issue 3 – Efficient Use of Resources and Costs Comments: We have no specific comments at this time on this matter. Prioritization: • Is fully addressed by solution being developed in another workstream. Issue 4 - Roles and Responsibilities and a Holistic View of ICANN Comments: The community worked very hard on formalizing a clear mission. Efforts continue on an ongoing basis to expand our role beyond it. New procedures don’t need to be made to deal with this, we just need to keep our Board, staff, and GNSO leaders educated about the mission, and ensure they take on an active role in reviewing ongoing projects against that mission and decline initiatives that would take us beyond it. One of the largest problems we face seems to be that, even within the MSM Work Plan, there is no central repository that allows the community to easily understand and cross-reference all that we are currently engaged in. It’s the responsibility of the ICANN organization to build a centralized structure wherein workstreams can be organized and easily vetted to be determined to be within scope. It needs to be the responsibility of each SO and AC, and, in circumstances where the Board initiates processes the ICANN Board, to show that the new work: • falls within the scope of ICANN’s mission • is not being duplicated elsewhere • is appropriately integrated with other active workstreams • solicits public comments in a centralized fashion Anybody who wants to call on volunteers or community feedback should need to meet those requirements to be entered into a centralized system that unlocks access to community resources. Prioritization: • Should be discussed and addressed at a later time. Issue 5 – Representation, Inclusivity, Recruitment and Demographics Comments: Disparate work is being done across the ICANN community on these important issues. It feels siloed, and less effective than if the same issues were being tackled in a holistic manner. Further, initiatives like the Fellowship and NextGen programs that are designed to bring new talent into ICANN community often end up operating in silos of their own. Rather than learning about ICANN through immersion and collaboration with the community, these newcomers to ICANN primarily attend their own slate of sessions. We believe a more integrated approach to these programs could enhance their effectiveness, both in terms of educating newcomers and in ensuring they come back after their programs’ conclusions. Prioritization: • Must be addressed in the Evolving ICANN’s MSM Work Plan. Issue 6 - Culture + Trust + Silos Comments: Issue 5 and Issue 6 are intertwined. Together, they represent a larger conversation this community needs to have that no other existing programs effectively address. This is likely the most important conclusion from the Facilitator’s report, and we encourage next steps to further explore these combined issues. Many of the other recommended improvements will actually result in improvements in this area. Effective prioritization, standardization, transparency, etc., can also serve to improve these issues. Prioritization: • Should be discussed and addressed at a later time. Issue 7 – Complexity Comments: We have no specific comments at this time on this matter. Prioritization: • Is fully addressed by solution being developed in another workstream. Issue 8 – Consensus Comments: We have no specific comments at this time on this matter, but continue to support the GNSO’s PDP 3.0 development process. Prioritization: • Is fully addressed by solution being developed in another workstream. Concluding Comments Thank you for the opportunity to comment. We look forward to engaging further on this work as it continues.