[ALAC] ALAC Statement on the Label Generation Rules for the Root Zone - Second Public Comment Draft

Rinalia Abdul Rahim rinalia.abdulrahim at gmail.com
Tue Jan 8 10:55:25 UTC 2013


Dear ALAC and IDN WG,

Edmon and I have prepared a draft statement in response to: At-Large IDN
Variant TLD Program – Procedure to Develop
<https://community.icann.org/x/7YxEAg>and
Maintain the Label Generation Rules for the Root Zone in Respect of IDNA
Labels – Second Public Comment Draft
Workspace<https://community.icann.org/x/7YxEAg>
?

Please provide your comments on the wiki so that all input are captured in
one place.  The link above will take you to the wiki as well as this one -
https://community.icann.org/pages/viewpage.action?pageId=38046957.

Text pasted below for your information.

Best regards,

Rinalia

DRAFT 8 Jan 2013

*ALAC Statement on the IDN Variant TLD Program – Procedure to Develop and
Maintain the Label Generation Rules for the Root Zone in Respect of IDNA
Labels – Second Public Comment Draft*



*Acknowledgment of Project 2.1 Team Achievement***


The At-Large Advisory Committee (ALAC) commends the IDN Variant TLD Program
Project 2.1 Team for its efforts and contributions in establishing vital
procedures that will enable the delegation and management of IDN Variant
TLDs toward enhancing multilingualism and cultural diversity on the
Internet.

We appreciate the Project Team’s openness to input and we are pleased to
see the incorporation of some of our suggestions in the revised “Procedure
to Develop and Maintain the Label Generation Rules for the Root Zone in
Respect of IDNA Labels.”**



*The 2-Panel Process and Effective Outreach*

*
*

We reiterate our support for the 2-panel process in the development of the
Label Generation Rules for the root zone, which allows different IDN
language and script communities to form and move at their own pace in
implementing IDN Variant TLDs.



For effective outreach to various language and script communities that may
be interested in forming Generation Panels, we call on ICANN to ensure that
all announcements and reports related to the implementation of IDN Variant
TLD be published in multiple languages, particularly the languages
addressed by the Variant Case Studies and the ones recommended for
prioritization in the Procedure Document.**



*Limited Supply of Global Experts for the Integration Panel*

*
*

We note with concern that the supply of experts for the Integration Panel
is limited.  This limitation is problematic for the following reasons: (a)
It makes it challenging to ensure diverse cultural backgrounds among the
panel members; (b) It places the continuity of the Label Generation Rules
process at risk where communities that enter the process late may be
affected adversely; (c) It allows for the possibility of process capture by
a few experts.



We urge ICANN to ensure the sustainability of the Label Generation Rules
process for the global language and script communities, who are at
different levels of readiness to develop Label Generation Rules for their
specific script, writing system and language.  We recommend that ICANN
undertake strategies to secure a steady supply of expertise (which may
include the provision of appropriate incentives as well as capacity
building) while placing appropriate term limits that safeguard the process
against capture.



*Governance Oversight and the Public Comments Process*

*
*

We recognize that the Integration Panel requires independence to carry out
its task.  We wish to stress that this independence needs to be accompanied
with high standards of transparency and strong accountability measures.  The
Procedure Document specifies the ICANN Public Comments as the primary
governance oversight mechanism for the decisions of the Integration
Panel.  This
mechanism has certain weaknesses: (1) It has no review process; (2) It does
not include an appeal process for the decisions of the Integration Panel;
and (3) The challenges associated with the Public Comments process still
apply (e.g., participation of relevant stakeholders, sufficient comment
period, etc.).  It is imperative that ICANN address the weaknesses of the
proposed mechanism to support a transparent and accountable process of
developing Label Generation Rules for the root.



The Procedure Document points out the following: “There is an argument that
could be made that the population of the root LGR is making policy. In
which case, the current policy-making procedures in the ccNSO and gNSO
could be used.”  Unless there is a compelling reason as to why the Label
Generation Rules process should be independent of the oversight mechanisms
of the ICANN Supporting Organizations (SOs), the ALAC advises the ICANN
Board to authorize the respective SOs (i.e., GNSO and ccNSO) to oversee the
implementation of the proposed mechanism.  The appropriate governance
oversight measures should include periodic reviews, high standards of
transparency and accountability structures worthy of the ICANN bottom-up
multi-stakeholder model.  Furthermore, special emphasis on the effective
engagement and participation of affected linguistic communities would be
crucial throughout the LGR process.



*Enabling Policies*



Given the prioritization of IDNs in the new gTLD process, the ALAC strongly
advises the ICANN board and community to begin addressing the policies
required to render the procedures for IDN Variant TLD delegation
operational on an urgent basis.  Statistics from the Interim Report of the
IDN Program Project 6 on User Experience highlights that almost 20% of user
queries could be directed towards an IDN Variant TLD.  This means that
without the delegation of the IDN Variant TLD, almost 20% of users would
have a negative experience.  Without having the requisite enabling policies
in place to support the roll out of the new gTLDs, the prioritization of
IDNs would in fact significantly hurt consumer trust and serve as a
disservice to the IDN community.



*Communicating Convergence Effectively*

The Procedure Document indicates that, “the mechanism is not the last stage
in making determinations about IDN labels for the root. Rather, its output
is to be consumed by other ICANN procedures that actually determine whether
a particular label is allocated to someone, and whether it is delegated in
the root.”  We request that ICANN clarify how the various procedures and
processes interface, interact or converge against an estimated timeline for
the benefit of the community.


END



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