Comments of Michael Palage, PFF to Dept. Of Commerce National Telecommunications and Information Administration (NTIA) NOI on 'ICANN 3.0'

The Internet Corporation for Assigned Names and Numbers (ICANN) has strayed from the technical coordinating mandate originally envisioned in the 1998 White Paper and has become a quasi-monopolistic regulator accountable to no one but itself. This NOI provides the global Internet community the opportunity to deconstruct the current the failed ICANN 2.0 governance model and put in place an ICANN 3.0 governance model incorporating a "back to basics" approach (restoring ICANN's original mission) and implementing important "lessons learned" to make ICANN more responsive and accountable to its stakeholders. ICANN is also wrong in its haste to escape its Joint Project Agreement (JPA) with the Department of Commerce, by pointing to its completed [independent review] reports and subsequent public comments and declares 'Mission Accomplished!' without having fully implemented the changes recommended in those reports." Four overarching issues to address: - ICANN's Periodic Review of its internal operations and supporting organizations has failed, and has become nothing more than a "perpetual motion machine of public comments and documentation producing no meaningful results." Only a second Evolution and Reform Process can solve ICANN's current deficiencies; - ICANN must hardcode into its policies and its contracts the principle that its policies cannot supersede national laws; - ICANN must cease any operational role in technical infrastructure as required by its bylaws and focus instead on its mission as a technical coordinator; and - Congress must avoid "kicking the JPA can down the road" and instead provide much-needed leadership by creating a solid foundation for ICANN 3.0 in legislation after proper consultation with the Government Accounting Office.