On July 6th AT&T submitted an ATIS Incubator Frame for administrating U.S. ENUM implementation. ATIS is aggressively lobbying the Ad Hoc group for its ENUM business, supported most visibly by AT&T, Telcordia and the RBOCs.
There are also two proposals for an independent enum forum. An organization called International Internet Telephone Organization (IITO)submitted Introduction to Enum Forums which has as yet garnered no visible support.
And Worldcom submitted WorldCom Contribution for Independent ENUM Forum, written by an apparently well-intentioned, thoroughly telco-regulation-savvy and thoughtful Peter Guggina. It is supported most visibly and emphatically by new Ad Hoc member Vint Cerf, Worldcom's Senior VP of Internet Architecture -- and ICANN's Chairman. Dr. Cerf wants the ENUM Forum to proceed using IETF* processes as its model.
As a carrier there is no love lost between WorldCom and ATIS, WorldCom having dropped its ATIS membership last year. And Dr. Cerf advises this writer that he is participating in the Ad Hoc and newly forming ENUM Forum representing only WorldCom.
But this writer is unclear what Dr. Cerf's fiduciary responsibilities are as director and Chairman of corporate ICANN. ICANN's Conflict of Interest Policies discuss directors representing individual/outside interests at ICANN - but not the reverse, as is the case here.
A colleague notes that "compared to the money and power on the ENUM tree, DNS is nothing," and ICANN's interest in controlling ENUM is on record:
IAB ISSUES ENUM MANAGEMENT GUIDELINES DRAFT, "The Department of Commerce requests that, as part of the IANA functions, ICANN undertake administration of the [ENUM] ARPA TLD..." (Vint Cerf helped found the IAB);
ENUM POLITICS: WHO'S GOING TO CONTROL THE CASH COW?, "To the extent that enum
relies on .arpa," Cerf confirmed, "that aspect surely falls under ICANN responsibility."; and
ENUM CONTROL RESIDES IN ICANN REGISTRY CONTRACTS, "ICANN management believes that, when a registry operator seeks to provide services by leveraging the "DNS infrastructure" that it exclusively operates under its registry agreement with ICANN, those services should be subject to technical requirements and other policies developed through the ICANN process...Concerns have been voiced that the ENUM World initiative,
depending on how it develops, may impair a sound technical enum implementation based on open and non-proprietary standards. To address concerns of this type, the new unsponsored TLD Registry Agreement covers registry services provided by the registry operator concerning "Registered Names," whether they are at the second or a lower level."
July 2001 presentation: ICANN overview and PSO Topics, by Hans Kraaijenbrink, ICANN Director & Helmut Schink, ICANN Director, Possible PSO issues in ICANN: support enum, avoid conflicts by ambiguous names, if required enhance the UDRP [Vint Cerf comes to the ICANN Board by way of representing the PSO]; and
GAC VIII: Melbourne, 9-10 March 2001, Executive Minutes, The [ICANN GAC] Chair reported that ENUM is the big issue in convergence of technologies and as such we need more information about activity on ENUM. The WIPO representative advised that they were asked to collect material on technical solutions for name collision. Internet Protocol Version 6 (IPv6), gateway etc, maybe ENUM too. She noted that WIPO needs more information on this and would appreciate more comments from members. The member from the EU advised that they were trying to engage ICANN staff on how protections are applied to DNS
We note also that Dr. Cerf isn't the only ICANN representative at the ENUM Ad Hoc: Theresa Swinehart is a former WorldCom lobbyist heavily involved in the development of the UDRP. Ms. Swinehart now works for ICANN. And at least one other Ad Hoc participant is heavily involved in ICANN's internal policy processes.
So what are we to make of the sudden overt ICANN presence at ENUM, and its aggressive opposition to non-IETF-like processes? Where ATIS is only selling administrative services and though definitely telco-centric, has no policy setting function or agenda, ICANN functions governmentally and sets name/IP number space policy (perhaps by contract, but the results are the same if not more ominous.)
(Speaking of contracts, we've yet to ascertain to what extent ENUM registries and registrars accredited by ICANN will be constrained into applying ICANN policy to their ENUM businesses.)
Non-ICANNites remain somewhat oblivious to ICANN. My discussions with ENUM Ad Hoc participants not involved with ICANN or up on internet politics, reveal a dangerous naiveté as to ICANN's number/name space intentions and track record, and a scary belief that existing laws and due processes would prevail in the event of inappropriate ICANN intervention or capture of ENUM.
(I've been asked if I'd prefer outright U.S. government regulation of ENUM. My answer is yes: a modicum of due process and accountability beats the hell out of none.)
ICANN circumvented national and international trademark law with its invention and contractual imposition of the UDRP, with many national laws including U.S. legislation then changing to suit ICANN policy. Consequently, earlier this month the intellectual property section of the draft Free Trade Area of the Americas (FTAA) made a proposal that would obligate countries by law to use ICANN's UDRP for domain name dispute resolution.
For telco corporate and regulatory executives to suggest that ICANN couldn't or wouldn't do the same or worse in the NANP and E.164 numbering space, despite normally logical arguments to the contrary, reveals a smug complacency that plays right into ICANN's hands.
These aren't normal times, and ICANN doesn't play by normal rules.
*As one IETF Area Director explained it, "an IETF working group chair is the one who makes up his mind that the working group has consensus for requesting a document to move forward. How he does this is up to him." The IETF process offers open accessibility for innovative product/service invention, which is a wonderful thing, but given the informality of consensus processes, policy capture is often par for the course.
The IETF is run by the Internet Architecture Board, (IAB) which Dr. Cerf helped found. The IAB appoints the IETF Chair, provides architectural oversight for IETF protocols and procedures, serves as an appeal board for complaints of improper execution of the standards process, and acts as representative of the interests of the Internet Society -- whose board of directors Dr. Cerf just left.