[ALAC] Proposed Amendments to Base New gTLD Registry Agreement Workspace

[Rinalia Abdul Rahim]

Olivier,

My understanding from Staff is that the RSEP is not a back door for dotless
domains. Cyrus Namazy can explain and I am copying him.

Best regards,

Rinalia

On Monday, 27 June 2016, Olivier MJ Crepin-Leblond <ocl at gih.com> wrote:

> Dear ALAC members,
>
> I am currently looking at the public consultation on "Proposed Amendments
> to Base New gTLD Registry Agreement"
> https://community.icann.org/x/uBiOAw
>
> Reading through the material that was made available, it appears that the
> issue of Dotless Domains is coming up again.
>
> The ALAC went on record in 2012 which helped encourage the Board to
> prohibit dotless domains. The ALAC Statement, which you can find on
> https://atlarge.icann.org/advice_statements/7661
>
> In that Statement, the ALAC supported the SSAC advice in SAC053 which
> recommended the prohibition of dotless domains. The Board agreed with this
> and in the "current" round of new gTLDs, this prohibition took place. I
> have checked with Julie Hammer, our SSAC Liaison, whether the SSAC has
> changed its advice since SAC053. She has assured me that this was NOT the
> case.
>
> To summarize the concern, the proposed RA amendment creates a possible
> path to approval of dotless domains using the RSEP process, which has the
> potential to circumvent the existing prohibition.
>
> In further details:
>
>    - On May 31, ICANN posted proposed amendments to the New gTLD Registry
>    Agreement for public comment
>    <https://www.icann.org/public-comments/proposed-amend-new-gtld-agreement-2016-05-31-en>.
>    These amendments have been under discussion between the Registries
>    Stakeholder Group (RySG) and ICANN for 18 months. The public comment period
>    closes on July 13 and there is a cross-community session scheduled at 10:30
>    a.m. on Tuesday in Helsinki.
>
>
>
>    - In 2012 and 2013, the SSAC
>    <https://www.icann.org/en/system/files/files/sac-053-en.pdf>, IAB
>    <https://www.iab.org/documents/correspondence-reports-documents/2013-2/iab-statement-dotless-domains-considered-harmful/>,
>    ALAC
>    <http://atlarge-lists.icann.org/pipermail/alac/attachments/20130611/2e639e17/CoverLetter-AL-ALAC-CO-0613-01-00-EN-0001.pdf>
>    *,* GAC
>    <http://archive.icann.org/en/meetings/durban2013/bitcache/GAC%20Communiqu%c3%a9%20-%20Durban,%20South%20Africa.pdf>,
>    and the ICANN Board
>    <https://www.icann.org/resources/board-material/resolutions-new-gtld-2013-08-13-en#1.a>
>    all recognized the risk posed by any  introduction of dotless domains in
>    new gTLDs.
>
>
>
>    - In August 2013, the ICANN Board’s New gTLD Program Committee (NGPC)
>    voted
>    <https://www.icann.org/resources/board-material/resolutions-new-gtld-2013-08-13-en#1.a>
>    to prohibit dotless domains.
>
>
>
>    - The proposed New gTLD Registry Agreement (RA) amendments include a
>    change in Exhibit A (Approved Services) related to dotless domains. While
>    it states appropriately that dotless domains are not permitted, it
>    intentionally or inadvertently introduces a new path for approval of
>    dotless domains via the Registry Services Evaluation Process (RSEP).  The
>    relevant language is below:
>
>
>
>    - (Note:  The above language effectively does not allow, among other
>       things, the inclusion of DNS resource records that would enable a dotless
>       domain name (e.g., apex A, AAAA, MX records) in the TLD zone.) If Registry
>       Operator wishes to place any DNS resource record type or class into its TLD
>       DNS service (other than those listed in Sections 1.1 or 1.2 above), it must
>       describe in detail its proposal and submit a Registry Services Evaluation
>       Process (RSEP) request.  This will be evaluated per RSEP to determine
>       whether the service would create a risk of a meaningful adverse impact on
>       security or stability of the DNS.  Registry Operator recognizes and
>       acknowledges that a service based on the use of less-common DNS resource
>       records and/or classes in the TLD zone, even if approved, might not work as
>       intended for all users due to lack of software support.
>
>
>
>    - The explanatory notes accompanying the proposed amended RA do not
>    explain why this change creating a path to approval of dotless domains has
>    been included, and there has been no change in the position of the ICANN
>    Board, IAB, SSAC, GAC or ALAC on this issue. Unlike the previously stated
>    positions of those entities, ICANN’s explanatory notes are silent. How and
>    why was this language included in the proposed amendment? It appears to be
>    pointless to propose a path to try and circumvent such a clearly
>    established prohibition.
>
>
>
>    - Using the RSEP process in this manner risks demoting any future
>    evaluation of registry proposals on dotless domains to ICANN staff without
>    appropriate policy work and/or community consideration.
>
>
>
>    - Introduction of this proposed use of RSEP is inappropriate and it
>    should be removed. In light of the ICANN Board’s August 2013 resolution and
>    the significant security and stability concerns raised by the IAB and SSAC,
>    dotless domains should instead receive the same treatment in the New gTLD
>    RA as Wildcarding, which is explicitly prohibited in Section 2.2.
>
>
>
> I look forward to your feedback and hope that the ALAC will make a
> Statement about this issue in response to the Public Consultation on
> Proposed Amendments to Base New gTLD Registry Agreement. Perhaps should we
> include in our Statement a direct question to the SSAC asking whether their
> advice has changed? This way, they would be able to respond to  the public
> record accordingly.
>
> Kindest regards,
>
> Olivier MJ Crépin-Leblond
>
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