At the forum held in Melbourne last Friday to develop a response to the US
Dept of Commerce Green Paper upon the DNS a brief one-page submission was
requested from IIA/ADNA that could be both sent on behalf of those
represented, as well as adopted and sent separately by those interested.  A
fuller response will be be delivered via NOIE at a later date.  While we
didn't manage to keep it to one page, the result is attached.

The response can be sent via email to dns§ntia.doc.gov, and must be
delivered by the end of today, March 23rd.  Further details on submitting
can be found at
http://www.ntia.doc.gov/ntiahome/domainname/022098fedreg.txt.  

An ASCII copy of the response as well as a Word 97 attached version are
included below.  Don't forget to change the attribution in the attachment
if you want to send it under your own name. . .



Regards,

Luke Carruthers
Secretary, IIA
Acting Chair, ADNA


-------------------------


March 21, 1998

Ms Karen Rose
Office of International Affairs
National Telecommunications and Information Administration 
Room 4701
U.S. Department of Commerce
14th and Constitution Avenue, N.W.
Washington, D.C. 20230
United States of America


Dear Ms Rose,

Re:  Improvement of Technical Management of Internet Names and Addresses

This letter is a response to the Green Paper concerning DNS issued by the
US Department of Commerce.  It outlines in brief some issues that the
Australian Internet industry has with the content of the Green Paper, and
some suggestions by which the proposal contained therein could be improved.
 We hope that with these suggestions and those put forward by other
interested parties, an effective and appropriate system for the management
of Domain Names can be implemented.

This response is submitted by the Australian Internet industry, coordinated
by the Internet Industry Association (IIA), Australia's peak representative
body for organisations commercially involved in the Internet, and
Australian Domain Name Administration (ADNA), the representative body
charged with the restructuring of the DNS within Australia.  Further
information regarding IIA can be found at http://www.iia.net.au.  Further
information regarding ADNA can be found at http://www.adna.asn.au. 

This submission is intended to be brief, with further comment to be
submitted through the Australian government in due course.

There are four primary issues this submission intends to address:
governance, competition, self-regulation versus regulation, and jurisdiction.


1. Governance
It is the Australian Internet industry's view that the body most
appropriately responsible for the DNS is a newly reformed IANA (Internet
Assigned Numbers Authority), with a governing board formed both from US and
international interests.  Australia, by virtue of its place as the fifth
largest user of the Internet, should be represented upon this board, though
it is more important that the appropriate processes be put in place than
the interests of any one country be pursued. Incorporating the new IANA as
a US company leads to a number of issues regarding jurisdiction, as
referenced below. 

2. Competition
The function of the registry, the database of Domain Names and associated
information, must be a matter of public trust, as this is the only way to
ensure that the interests of the end user are adequately served.
Accordingly it is not an appropriate place for competition.  It is however
appropriate that the registrar function, the registration of Domain Names,
is an area of competition, as this will serve to provide the greatest
benefit to the end user in both pricing and quality of services.

3. Self-regulation versus Regulation
The Australian industry is particularly experienced in self-regulation,
having pursued this approach for a number of years in many fields including
telecommunications.  It is our view that self-regulation is preferable to
government regulation.  This enables all stakeholders to be represented in
discussions, without being restricted by the problem of which country's
government is appropriate in which circumstance.  Self-regulation needs to
be backed up by a light regulatory framework however, and where
international bodies with responsibility for particular areas (such as the
World Intellectual Property Organisation) exist, these bodies may be able
to provide this regulatory support.  

4. Jurisdiction
Jurisdiction over registrar operations must be divided between DNS'
governing body and the country within which the registrar is operating.
Jurisdiction over the DNS' governing body (assuming, as suggested above, a
reformed IANA governed by an international board) is a more problematic
area however, with no clear solution. 


It may not be practical to have participation by each and every country (or
party) that may wish to do so. Equally it would be grossly improper for the
United States to take an overbearing role in such a clearly international
area. Our suggested approach would be for a model similar to that of the
United Nations Security Council, with appropriate representation by the key
players together with implied obligations to those parties not directly
represented.

As a final point, it is the strong recommendation of the Australian
industry that wider international consultation must be carried out before
the implementation of any process that has such a great effect upon
international industry.  The DNS is one of the foundations of electronic
commerce, and will have an impact upon billions of dollars worth of future
revenues for many countries.  It is too important an issue to be decided
upon without the full involvement of industries in all countries that make
up the electronic marketplace.


Yours sincerely,



Luke Carruthers

Acting Chair
Australian Domain Name Administration

Secretary
Internet Industry Association

Attachment converted: Obnoxious:Response to Green Paper on DNS. (WDBN/MSWD) (00011FEC)