[ALAC] Proposed Amendments to Base New gTLD Registry Agreement Workspace
Rinalia Abdul Rahim
rinalia.abdulrahim at gmail.com
Tue Jun 28 08:14:57 UTC 2016
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.
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"
> 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
> 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
> 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
> 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
> *,* GAC
> and the ICANN Board
> 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)
> 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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