VZCZCXRO3992
PP RUEHAG RUEHDF RUEHIK RUEHLZ
DE RUEHVI #2054/01 1911214
ZNR UUUUU ZZH
P 101214Z JUL 06
FM AMEMBASSY VIENNA
TO RUEHC/SECSTATE WASHDC PRIORITY 4185
INFO RUCNMEM/EU MEMBER STATES COLLECTIVE

UNCLAS SECTION 01 OF 02 VIENNA 002054 
 
SIPDIS 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: ECON ECPS ETRD EINT ETTC AU
SUBJECT:  Inviting Input Concerning the ICANN's 
Management of the Internet Domain Name and Addressing 
System (DNS) 
 
REF:  (A) STATE 108105; (B) VIENNA 1685; (C) STATE 89981 
 
¶1.  Per ref A instructions, Post followed up with the 
responsible government authorities and the private sector 
"Internet Service Providers Austria" (ISPA) about their 
preparedness to participate in the NTIA's public 
consultation process. 
 
¶2.  Dr. Christian Singer, head of legal services in the 
telecom and postal services directorate of the Federal 
Ministry for Transportation, Innovation and Technology 
told us that his ministry and the Federal Chancellery's 
media office will refrain from sending a separate comment 
on behalf of the GoA to the NTIA's public consultation 
process.  They will continue coordinating GoA views with 
other EU member states within the High-Level Group on 
Internet Governance (HLIG), where ICANN management was an 
issue during last week's meeting. 
 
¶3.  ISPA sent its comment directly to the NTIA's e-mail 
address at: dnstransition@ntia.doc.gov.  For convenience, 
we repeat ISPA's comment below: 
 
Begin text. 
 
To the 
National Telecommunications and Information 
Administration, 
U.S. Department of Commerce 
DNSTransition@ntia.doc.gov 
 
Vienna, 7th of July 2006 
 
Dear Madam, 
Dear Sir, 
 
We, the ISPA - Internet Service Providers Austria, the 
association of ISPs in Austria and a key stakeholder of 
the Local Internet Community were invited to comment on 
ICANN's management over the Internet domain system and 
addressing system, and are grateful for that opportunity. 
We note that the registry for the at TLD is also member 
of the ISPA and managing directors are represented on the 
ISPA executive board. 
 
nic.at GmbH, seated in Salzburg, Austria is the official 
registry for .at domains, and therefore subject to 
Austrian law.  nic.at has been providing the registry 
service under supervision of the  Local Internet 
Community as represented on its Domain Name Council since 
1998 in an open and transparent way. The ISPA - 
representative of ISPs and registrars - would like to 
emphasize the fact that the entire LIC in Austria is very 
satisfied with nic.at GmbH's performance. 
 
Our views on your inquiry are as follows: 
 
--  We support the concept of ICANN acting as the global 
coordinator and enhancing stability of the Internet all 
over the world. 
 
--  We support private sector leadership and a bottom-up 
approach to decision-making. 
 
--  We consider national governments an important part of 
the LIC, among other stakeholders. 
 
--  We believe ICANN should concentrate on its core 
mission (stability and coordination) and reduce policy 
activities to a minimum.  In particular, ICANN shall in 
no way be involved in decisions better left to the local 
community. 
 
--  According to the WSIS declaration, no other country 
or organisation shall decide on ccTLD policy.  This 
declaration shall also apply to ICANN. 
 
--  The involvement of all stakeholders (including 
governments) within the ICANN processes is important, and 
be performed through appropriate bodies within the ICANN 
context. 
 
--  In our view, a contractual arrangement with ICANN and 
ccTLD's is neither necessary nor desirable.  We 
understand nic.at GmbH is willing to provide a reasonable 
contribution to ICANN's expenses, relating to the IANA 
operating cost. 
 
--  The IANA function should be streamlined and 
automated, for instance by using the e-IANA software.  We 
underline that substantial progress has been made with 
respect to IANA process backlog and organisational 
 
VIENNA 00002054  002 OF 002 
 
 
structure, and acknowledge the major contribution of 
David Conrad and his team. 
 
--  We do not understand why the DoC still has control 
over, and approves of changes in the .at root zone 
entries.  We consider these an exclusively national 
matter. 
 
--  We welcome ICANN's IDN and internationalisation 
efforts, but see a limited impact on registries like 
nic.at.  We do welcome the DNSsec initiative, and note 
that a signed root zone would be a major step forward. 
 
--  We believe additional gTLD's are of limited value - 
the TLD business is highly competitive, there is no 
scarcity in the DNS namespace, and we suggest to keep in 
mind that many new gTLD efforts have turned out as flat- 
out failures. 
 
--  We consider ICANN a policy-making body for gTLDs, but 
not for ccTLD's, as stated above. 
 
--  We would particularly welcome Service Level 
Agreements with IANA and understand nic.at GmbH would be 
willing to contribute funds to achieve them. 
 
--  We note that a detailed budget for IANA (cost and 
expense) are lacking. 
 
 
Overall, we support the ICANN concept. However, we 
consider the out-of-scope policy making attempts and the 
ballooning ICANN budget as issues to be addressed. 
 
We are grateful for the opportunity to express our point 
of view and remain 
Yours truly 
 
Dr. Kurt Einzinger 
General Secretary 
ISPA - Internet Service Providers Austria 
Waehringerstrasse 3/18 
1090 Wien, Austria 
Tel.: +43 1 409 55 76 
Mail: kurt.einzinger@ispa.at 
web: http://www.ispa.at 
 
End text. 
 
MCCAW