Below (and attached) is the comment of ICANN’s Business Constituency (BC), on Evolving the Governance of the Root Server System. The BC welcomes the opportunity to provide comment on a New Cooperation and Governance Model for the Root Server System We have reviewed RSSAC037<https://www.icann.org/en/system/files/files/rssac-037-15jun18-en.pdf> (A Proposed Governance Model for the DNS Root Server System), RSSAC038<https://www.icann.org/resources/files/1216343-2018-06-15-en> (RSSAC Advisory on the proposed Governance Model for the DNS Root Server System), New Cooperation and Governance Model for the Root Server System<https://www.icann.org/en/system/files/files/rss-governance-model-concept-pap...> and Draft Work Plan for RSS Governance Working Group (GWG) and ICANN Org<https://www.icann.org/en/system/files/files/draft-rss-gwg-charter-work-plan-...>, all by the ICANN Root Server System Advisory Committee (RSSAC). Assessment Our assessment is that a development that integrates RSS governance and accountability within the global multi-stakeholder structure of ICANN is welcome, and that the proposed three-part structure comprised of a Root Server System Governance Board (RGB), a Root Server System Standing Committee (RSC) and a Root Server Operator Review Panel (RRP) is a practical mechanism for this integration. Concern While we believe that the governance model proposed is apt and balanced, we also are concerned that ICANN Org as a root operator itself could be faced with conflict of interest. The question is, Would ICANN Org be accountable also to the RSS Governance Board (RGB)? It is BC’s view that if the structural mechanism is to work well, accountability and balance can be achieved but the optimum would be for another independent body to operate the L-root currently operated by ICANN. We notice that review of potential conflicts of interest are addressed in the GWG Draft Work Plan, but these are seemingly limited to the Finance and Secretariat functions and not to the L-root server concern expressed here. Suggestion On page 9 under Section 3.1 Root Server System Governance Working Group and on the requirement of the Working Group to Regularly report to the ICANN Board and ICANN community on its progress. We would like to suggest that the work 'regularly' be defined to be either monthly or quarterly or a week before regular ICANN board meetings. Clarification request On the document RSSAC037 page 8: Introduction. We are trying to reconcile the first statement The RSS began at the Information Sciences Institute (ISI) in 1984; and a subsequent statement on the 2nd paragraph which says After more than four decades of evolution, today’s RSS features root server operators (RSOs) from diverse organizations. We would appreciate clarification to know what is meant here because four decades after 1984 is 2024 and we are currently in 2019. Overall, the BC supports this model. -- This comment was drafted by Jimson Olufuye and Mark Svancarek. It was approved in accord with our charter. -- Steve DelBianco Vice Chair for Policy Coordination ICANN Business Constituency (BC)