ISP & Connectivity Providers Constituency
Constituency Comments on the ‘Affirmation Reviews’ 

This document reflects the views of the Internet Service Provider and Connectivity Providers Constituency (ISPCP) on the Affirmation Reviews. 
The Affirmation Reviews represent a significant step forward for ICANN which will support its independence and acceptance as the body responsible for the coordination of the Internets unique identifiers. As such, it’s essential that the mechanisms proposed fully support a framework that will ensure full accountability and the fair and transparent involvement of the multi-stakeholder community. It is also essential that the process remains open to further improvement, base on experience gained and ongoing dialogue with the stakeholder community.
The ISPCP considers the timetable for the Review process is extremely challenging; this is especially true for the first review on Transparency and Accountability.  This timeframe in particular does not allow for broad consideration of either candidates or the process, a fact underlined by the call for candidates being made prior to the conclusion of comments on the proposals. This does not send a positive message to the community. Whilst appreciating the need for timeliness, imposing unrealistic timescales often has a negative impact. The constraints placed upon the first review must be taken into account when the output is considered, and the possibility of an additional review being required within a shorter timeframe may require discussion upon its completion.

The independence and composition of the Review Teams forms a critical element of the proposals. Therefore full transparency throughout the selection process is important, including the selection of independent experts. Without this, the required level of confidence will not be achieved
Whilst ICANN now represents a well proven and effective model that facilitates the innovation and dynamism so essential for the development and deployment of the internet, the multi-stakeholder model can still appear complex to those who have not been involved. It’s therefore important that those who have experience and a thorough knowledge of the ICANN process are fully involved in the Review Teams. The involvement and role of an external consultant (Section 2 of the draft) needs to be carefully considered against this background. Whilst support can be offered for this proposal it has to be on the basis that their role is to facilitate and support the process in conjunction with the Review Team, not to perform the evaluation. 
Throughout the Review Teams its essential there is a balance of expertise and diversity. It is more important to ensure the Review Teams exhibit balanced representation than to meet arbitrary limits on size. Whilst appreciating the Team cannot be allowed to grow in a manner that impacts either its effectiveness or its ability to deliver, limiting the number of Review Team members to 7 or 8 imposes a constraint that would severely restrict its ability to achieve a level of representation that is acceptable to the community. The ISPCP supports the view that the size of the team must be extended. 
For the review of Accountability and Transparency, with the GNSO being a major source of ICANN’s policy formation process, involving just two representatives from that part of the community is not considered appropriate. Particularly as the GNSO is now divided into two distinctly separate Houses with a broad participation of stakeholders. The ISPCP proposes four GNSO representatives should be involved.
It is further suggested that the review on Competition Consumer Trust and Choice should facilitate representation of at least two members of the GNSO in order to cover the diverse make up and different perspectives that exist.