[NCSG-Discuss] Should NCSG consider filing an ombudsman complaint against ICANN senior staff for violating the organization's policy development process?

[Dan Krimm]

A seemingly simple and yet actually tricky question.

There are multiple ways that ICANN can be "an international body"...

There is the GAC of course.  International in the sense that nations can
participate as nations.

There is ALAC, with its regional hierarchy, formally international in its
representation structure.

And then there are the SOs, which can admit members from around the world.
 Especially the ccNSO is explicitly internationalized following the
internationalization of the ccTLDs.  But GNSO SGs obviously admit
international members too, such as NCSG admits members from all over.

So, the MSM has these multiple, parallel expressions of internationalism.

All inside the bottle.

As long as USG keeps its hands off the MS governance process (which it has
tried to do from the beginning), the existing internationalism has a
potential to operate in all of these ways.  While none of these is perfect
in and of itself, at least there is some attempt to enable international
voice in policy-making in more than one formal manner.

So, if one wants to preserve and build on this internationalism, one ought
to want to fix the MSM from inside the bottle.  If we call in the parents,
they are all USG, and then there will likely be outcry that USG is getting
preferential treatment.

That's one aspect of unintended consequences for taking such action, and
should be prepared for if indeed such action is pursued.  OTOH, the
unintended consequence of USG taking a hands-off attitude to ICANN MS
governance is that the kids are messing up the game.  This is the Achilles
Heel of all QUANGOs, unless they set up effective and formal
public-interest oversight structures.  Is an international governance
process acceptable if the bottom-up aspect of that process is subverted by
narrow interests using ad hoc pathways enabled by staff outside the MS
process?

In that case, the process is only as international as the staff itself,
when the staff call the shots.  I think ad hoc process pre-empts the
internationalization issue.  All bets are off.

The establishment and entrenchment of powerful ad hoc staff procedures to
circumvent MS governance IMHO represents brinksmanship and a "nuclear
option" with regard to MS governance.  It just calls out for other
"nuclear option" responses, like going to USG if we can't fix the mess
inside the bottle.

In some sense, this represents all of the long-standing governance issues
at ICANN coming to a head, after brewing under the surface for well over a
decade.  The time bomb is apparently finally ticking down.

Dan


-- 
Any opinions expressed in this message are those of the author alone and
do not necessarily reflect any position of the author's employer.



On Wed, March 27, 2013 2:06 pm, Alain Berranger wrote:
> Thanks Dan,
>
> ...very clear and for my own purpose quite educating...
>
> Can the current ICANN structure actually devolve into an international
> body
> while maintaining a judicial or regulatory body under US law only?
>
> Alain
>
> On Wed, Mar 27, 2013 at 4:56 PM, Dan Krimm <dan at musicunbound.com> wrote:
>
>> Alain,
>>
>> Back for a while, in flight.  I'm not sure exactly what you are saying
>> when you say:
>>
>> > The sharp line in the sand distinction in an organization between
>> policy
>> > and implementation is arbitrary if you have an independant judiciary
>> > function or an oversight/regulatory body above the organization.
>>
>> There is certainly a sharp line in the sand for example in USG
>> governance:
>> policy is made by Congress and implemented by the Administration.  So,
>> statute defines the policy writ large, and regulations define the
>> execution of that policy in detail.  And the independent courts
>> interpret
>> any fuzzy areas of statute, and oversee the regulation from the
>> standpoint
>> of the statute and case law, and with regard to procedural matters.
>>
>> In the case of ICANN, its authority comes from the USG executive branch,
>> but given the "internal" MS governance structure, the USG judiciary does
>> not currently get involved in policy/implementation issues "inside the
>> MS
>> bottle" and even the NTIA does not concern itself with "details" on any
>> sort of ongoing basis -- NTIA does not micromanage ICANN.
>>
>> So at present any such judicial or regulatory body outside ICANN is not
>> affecting ICANN's activities in any important manner.  If there is going
>> to be such oversight, either it has to occur inside the bottle as a
>> feature of MS governance structure, or else the external oversight
>> functions would need to be activated somehow.
>>
>> I've argued recently that if this can't be fixed inside the bottle, we
>> should definitely explore activating that external authority.  As you
>> say
>> (I think?), think outside the ICANN box (or bottle). One must of course
>> recognize that this would be a dramatic course of action, never having
>> occurred previously in the history of the organization. As Avri said
>> earlier, this would represent an admission that the MSM has in fact
>> failed, and the "parents" are being brought in to clean up the kids'
>> mess.
>>
>> ICANN was not supposed to operate as a normal (nonprofit) corporate
>> organization.  That corporate framework was just supposed to set up an
>> operational infrastructure within which a completely new governance
>> structure could be set up.  The corporate framework was not supposed to
>> get involved in the real meat of governance, just to execute those
>> policies after development by a bottom-up MSM and approved by the Board
>> (or sent back to MSM for further work).
>>
>> Staff was never supposed to have any significant policy-making power of
>> its own, AIUI.  But, in the real world it is certainly true these
>> distinctions are fuzzy at best.  In Congress for example, legislators'
>> policy-expert staff have a great deal of individual influence over the
>> writing of legislation.  Of course, lobbyists also can have a great deal
>> of influence in writing legislation.
>>
>> Bottom line, don't think of ICANN governance as that of the NPOcorporate
>> framework itself.  That's the bottle.  What's in the bottle(MS policy
>> making) is supposed to be independent of the bottle as much as possible
>> --
>> the bottle is only meant to facilitate and implement policy, not to
>> direct
>> or constrain the formulation of policy.
>>
>> If this distinction has been lost, the MS governance process itself has
>> been lost, or at least co-opted.  It's worth seeing if we kids can clean
>> up the mess on our own, but if not let's definitely consider if and when
>> to bring in the parents to do it for us.  Alas.
>>
>> Dan
>>
>>
>> --
>> Any opinions expressed in this message are those of the author alone and
>> do not necessarily reflect any position of the author's employer.
>>
>>
>>
>> On Wed, March 27, 2013 11:48 am, Alain Berranger wrote:
>> > Dan,
>> >
>> > Thank you for that moment of opportunity!
>> >
>> > The sharp line in the sand distinction in an organization between
>> policy
>> > and implementation is arbitrary if you have an independant judiciary
>> > function or an oversight/regulatory body above the organization.This
>> > distinction has been "invented" at ICANN to protect GNSO's territory -
>> > policy - and leaving implementation to "staff"... It is a mine field,
>> from
>> > what I have seen since I joined ICANN in San José and the discussion
>> > between policy and implementation is flawed by design.... but makes
>> for
>> > passionate discussions...and will for a long time to be.
>> >
>> > I do not know who the ICANN ombudsman reports to (I have not done the
>> > research) but his office does not seem to have the authority or the
>> > resources to dictate to ICANN what to do. It should report to the
>> Board
>> in
>> > any case and maybe it does? But where is the bigger ICANN oversight?
>> How
>> > do
>> > you move from the current situation, as described by Dan, to a truly
>> > international organization (some of the very first words of our CEO
>> last
>> > summer)?
>> >
>> > Normally, a corporation or an NGO  or a government dept has a policy
>> dept
>> > which makes evidence-based policy recommendations. These go to the
>> Board
>> > for decision, weighting in all the factors, internal and external,
>> that
>> > impact on the mission.
>> >
>> > We need to think outside the ICANN box on this one!
>> >
>> > Alain
>> >
>> > On Wed, Mar 27, 2013 at 2:13 PM, Dan Krimm <dan at musicunbound.com>
>> wrote:
>> >
>> >> Alain,
>> >>
>> >> Thanks for the discussion.
>> >>
>> >> First, I think we should file all Ombudsman complaints (and
>> definitely
>> >> recruit allies), though I don't expect it would necessarily be a
>> silver
>> >> bullet solution -- holding it to that standard would make it appear
>> >> ineffective.  But it builds a track record, a case that we are trying
>> >> everything pro forma, jumping through the hoops as expected, playing
>> the
>> >> procedural game, the bureaucracy, as specified.  We climb the ladder
>> one
>> >> step at a time, appealing to ever greater authorities like in the
>> court
>> >> system.  This is the step of establishing facts, formal basis of
>> >> objection, etc.
>> >>
>> >> Next, the difference between what you call closely vested interests
>> and
>> >> principled interests exhibits one well-known characteristic: the
>> >> "collective-action problem".  Vested interests tend to be narrow
>> >> interests, whereas principled interests tend to be broad interests.
>> >> Narrow interests that are well-endowed are always at a relative
>> >> advantage
>> >> compared to broadly distributed interests, because while there may be
>> >> enough resources distributed broadly to counteract the concentrated
>> >> resources of narrow interests, there is a much higher cost to
>> >> motivating,
>> >> coordinating and marshaling distributed resources.  The cliche that
>> >> comes
>> >> to mind is "herding cats".  Especially, since all participation in MS
>> >> processes at ICANN is on a volunteer basis, narrow interests can much
>> >> more
>> >> easily allocate paid resources to this volunteer activity, whereas
>> >> distributed interests have a much harder time making this allocation.
>> >>
>> >> This dynamic has been present at ICANN as long as I've been involved,
>> >> which goes back to 2006.  I suspect it has been this way from the
>> start
>> >> --
>> >> it's a structural dynamic that relates to the whole SO organizational
>> >> model.
>> >>
>> >> Soto your question, how does a MS organization balance this inherent
>> >> imbalance in the ability to participate effectively?  The big-picture
>> >> answer is that the little guys at the bottom of the pyramid need to
>> be
>> >> given ways to neutralize the resource advantage. Not to be given any
>> >> special advantage above narrow interests, but to play on a level
>> playing
>> >> field.
>> >>
>> >> One obvious tactic is to create formal operational structures that
>> >> enable
>> >> bottom-up participation without doing anything to disadvantage those
>> >> with
>> >> the resources to participate in other ways.  There has been some
>> effort
>> >> to
>> >> do so at ICANN, but this is constantly being undermined by the narrow
>> >> interests -- if policy is a "war" then opponents will seek to win the
>> >> war
>> >> any way they can, and that can involve tweaking the rules of the game
>> to
>> >> one's advantage, if they are being systematically set up to reduce
>> one's
>> >> advantage.
>> >>
>> >> So, if there is a structure to provide equitable participation,
>> finding
>> >> an
>> >> ad hoc alternative path to avoid that equity is again to one's
>> >> advantage,
>> >> to the extent that equity is a reduction in influence.
>> >>
>> >> Separation of power in a governance structure is imperative if equity
>> is
>> >> to be maintained.  One big problem with ICANN is that there is little
>> >> evidence of the equivalent of an "independent judiciary" in the org
>> >> structure.  If there is no distinction between the executive and
>> >> judicial
>> >> functions, then the executive hierarchy is unchecked.
>> >>
>> >> In short, ICANN used a conventional non-profit organizational
>> structure
>> >> with weak oversight from the USG (DoC/NTIA) to create a "bottle" in
>> >> which
>> >> the MSM was intended to operate.  A sort of "virtual world" of
>> >> governance.
>> >>
>> >> But within that virtual world of governance, the staff has embedded
>> >> itself
>> >> in policy-making, rather than just being part of the bottle, which
>> was
>> >> presumably what it was intended to do.  AIUI, staff was supposed to
>> >> provide infrastructure, not to get involved in the content of MS
>> >> activity.
>> >>
>> >> This Chinese Wall has been breached.  So one prerequisite is that
>> staff
>> >> needs to be confined to acting as only the bottle, once again. In
>> order
>> >> for that to happen, there needs to be some independent oversight of
>> >> staff
>> >> to prevent policy-relevant activity.
>> >>
>> >> Several folks have mentioned the policy/implementation split.  This
>> is
>> >> part of that problem: implementation can be considered part of the
>> >> bottle,
>> >> but policy must be seen as only "contents" of the bottle.  Fudging
>> this
>> >> split is a major way to break through the Chinese Wall.  So I think
>> this
>> >> point should be pressed firmly, front and center, not as some sort of
>> >> tangential point.
>> >>
>> >> Another conceptual problem is that ICANN in practice is not just an
>> >> "operational organization" -- the policies it makes can have profound
>> >> political ramifications, and thus politics gets into the picture in
>> >> practice, even if the terms of discourse center on operational
>> >> principles.
>> >>
>> >> There is frequent mention of keeping ICANN to just operational
>> matters
>> >> (I'm definitely a proponent of that mission), however it should be
>> >> acknowledged that such a position is inherently political: it's all
>> >> about
>> >> protecting the broadly-distributed interests against narrow
>> interests,
>> >> and
>> >> the broad-narrow contest is fundamentally political.
>> >>
>> >> I'm afraid I don't have the time to pound on ICANN's org structure
>> from
>> >> a
>> >> detailed theoretical basis (part of that difficulty of resource
>> >> allocation: I don't get paid to do this, and I need to get to do
>> >> *something*,so that competes for my time).  I wish I could.  The only
>> >> reason I can offer this contribution right now is that I'm traveling
>> and
>> >> currently waiting at the airport for a flight -- one fleeting moment
>> of
>> >> opportunity (more moments on the flight, a bit later).
>> >>
>> >> These are big questions, and deserve big answers.  I don't have those
>> >> answers in any detailed form, because that takes a lot of work to
>> make
>> >> one's way through the forest at the individual-tree level.
>> >>
>> >> Suffice it to say that as the MSM at ICANN has "matured" the narrow
>> >> interests have found ways to twist both the bottle and the contents
>> to
>> >> their systematic advantage, which the MSM was intended to neutralize
>> >> (since they start with the advantage naturally, without special
>> efforts
>> >> to
>> >> privilege them).
>> >>
>> >>
>> >> At this point, we take the system as it stands and do everything
>> >> possible
>> >> to get it to work, but as I said earlier, I think we should be
>> prepared
>> >> to
>> >> address everything -- the bottle and not just the contents -- to push
>> >> for
>> >> the distributed-interest agenda.
>> >>
>> >> Dan
>> >>
>> >>
>> >> --
>> >> Any opinions expressed in this message are those of the author alone
>> and
>> >> do not necessarily reflect any position of the author's employer.
>> >>
>> >>
>> >>
>> >> On Wed, March 27, 2013 8:45 am, Alain Berranger wrote:
>> >> > Dear Robin, dear Colleagues:
>> >> >
>> >> > I agree that GNSO should file too... but will they (Maria's
>> question)?
>> >> Two
>> >> > complaints (GNSO + NCSG) are better than one (Avri's statement)...
>> >> >
>> >> > 3 questions:
>> >> >
>> >> > 1) From my little experience, I find the ICANN Ombudsman process
>> >> > ineffective - it is time consuming (we are volunteers/the other
>> side
>> >> is
>> >> > paid), a lot of pain for usually not much gain! Not saying we
>> should
>> >> not
>> >> > do
>> >> > it, just wondering out loud if we have a chance at all of being
>> >> > successful?
>> >> > or even partially successful? or if we should invest our time in
>> other
>> >> > ways?
>> >> >
>> >> > 2) Robin, I fully understand your TM arguments and they make sense
>> to
>> >> me
>> >> > as
>> >> > a non-specialist. Can you please elaborate a bit on who the
>> >> "*powerful
>> >> > political interests"* you refer to are? This may help me and others
>> at
>> >> the
>> >> > base of the NCSG pyramid understand the context and the issue
>> >> better...
>> >> >
>> >> > 3) Did Maria fill a complaint to the Ombudsman? and where is it at
>> >> now?
>> >> >
>> >> > 4) I also have a point of view or perhaps an hypothesis to share,
>> from
>> >> > many
>> >> > years of applied MS practice funding developmental and applied
>> policy
>> >> > research in developing countries - may not be relevant but here it
>> is
>> >> > anyway for feedback and reflexion...
>> >> >
>> >> > I see the MS process as one of fundamental inclusion and
>> >> participation...
>> >> > It is more relevant than ever because of the internet and the
>> networks
>> >> > that
>> >> > spring from it...
>> >> >
>> >> > ...the more you are at the bottom of the pyramid ($, knowledge,
>> assets
>> >> > like
>> >> > land ownership, cash, access to resources, etc...) the more you
>> seek
>> >> > participation as a way of climbing up the pyramid (getting yourself
>> >> out
>> >> of
>> >> > poverty). The higher you are in the pyramid, the less you welcome
>> >> > participation because it is disruptive at the very least.
>> >> >
>> >> > Inherent to this "MS model" is the power struggle between closely
>> >> vested
>> >> > interests (in our case the CHP and part of the NCHP) and higher
>> level
>> >> or
>> >> > principled interests (in our case  the rest of NCHP). Not that
>> there
>> >> are
>> >> > not closely vested interests as well as principled interests
>> >> everywhere
>> >> in
>> >> > an MS organization, including ICANN.
>> >> >
>> >> > Closely vested interests are very time sensitive (profits, status
>> and
>> >> > privileges are lessened by indecision and ambiguity - the rules of
>> the
>> >> > game
>> >> > are not clear driving the the "powerful political interests"
>> crazy!)
>> >> while
>> >> > principled interests are less time sensitive (although short term
>> >> costs
>> >> > are
>> >> > usually huge too) because they are universal.
>> >> >
>> >> > So here comes a question: How does an *operational organization*
>> like
>> >> > ICANN
>> >> > wishing to become better at MS behavior (we can assume that anyway
>> for
>> >> the
>> >> > eternal optimist) resolves the issue of closely vested vs.
>> principled
>> >> > interests?
>> >> >
>> >> > They are by nature in tension and should be... What is essential is
>> to
>> >> > keep
>> >> > a balance... For instance, taking just one of the financial
>> >> dimensions,
>> >> it
>> >> > is the DNS supply side that keeps feeding extra cash into ICANN and
>> >> the
>> >> > DNS
>> >> > demand side does not have the means to bring this in balance,
>> although
>> >> it
>> >> > is the market.... it is a bit of a class struggle (or concentration
>> of
>> >> > power differentials on the supply and demand sides) in the sense
>> that
>> >> if
>> >> > you do not keep this delicate balance the system will eventually
>> fail.
>> >> It
>> >> > is a matter of time!
>> >> >
>> >> > I for one would like to see ICANN survive as an MS organization,
>> being
>> >> > able
>> >> > to keep the "rapport de forces" in equilibrium.
>> >> >
>> >> > I would love to hear a criticism of this model's assumption and
>> also
>> >> > perhaps if it can help in bringing back balance... or is it simply
>> a
>> >> > theoretical treatment?
>> >> >
>> >> > Best, Alain
>> >> >
>> >> > On Wed, Mar 27, 2013 at 5:51 AM, Horacio T. Cadiz <hcadiz at ph.net>
>> >> wrote:
>> >> >
>> >> >> I support filing a case.
>> >> >>
>> >> >>
>> >> >> --
>> >> >> Bombim Cadiz
>> >> >> *******************************************
>> >> >> *  Free/Open Source Software (FOSS) --  *
>> >> >> * No windows. No gates. It is open.     *
>> >> >> * No Bill. It is Free.                  *
>> >> >> *******************************************
>> >> >>
>> >> >
>> >> >
>> >> >
>> >> > --
>> >> > Alain Berranger, B.Eng, MBA
>> >> > Member, Board of Directors, CECI,
>> >> > http://www.ceci.ca<
>> >> http://www.ceci.ca/en/about-ceci/team/board-of-directors/>
>> >> > Executive-in-residence, Schulich School of Business,
>> >> www.schulich.yorku.ca
>> >> > Treasurer, Global Knowledge Partnership Foundation,
>> >> www.gkpfoundation.org
>> >> > NA representative, Chasquinet Foundation, www.chasquinet.org
>> >> > Chair, NPOC, NCSG, ICANN, http://npoc.org/
>> >> > O:+1 514 484 7824; M:+1 514 704 7824
>> >> > Skype: alain.berranger
>> >> >
>> >> >
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>> > --
>> > Alain Berranger, B.Eng, MBA
>> > Member, Board of Directors, CECI,
>> > http://www.ceci.ca<
>> http://www.ceci.ca/en/about-ceci/team/board-of-directors/>
>> > Executive-in-residence, Schulich School of Business,
>> www.schulich.yorku.ca
>> > Treasurer, Global Knowledge Partnership Foundation,
>> www.gkpfoundation.org
>> > NA representative, Chasquinet Foundation, www.chasquinet.org
>> > Chair, NPOC, NCSG, ICANN, http://npoc.org/
>> > O:+1 514 484 7824; M:+1 514 704 7824
>> > Skype: alain.berranger
>> >
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>
> --
> Alain Berranger, B.Eng, MBA
> Member, Board of Directors, CECI,
> http://www.ceci.ca<http://www.ceci.ca/en/about-ceci/team/board-of-directors/>
> Executive-in-residence, Schulich School of Business, www.schulich.yorku.ca
> Treasurer, Global Knowledge Partnership Foundation, www.gkpfoundation.org
> NA representative, Chasquinet Foundation, www.chasquinet.org
> Chair, NPOC, NCSG, ICANN, http://npoc.org/
> O:+1 514 484 7824; M:+1 514 704 7824
> Skype: alain.berranger
>
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