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

Alan Greenberg alan.greenberg at mcgill.ca
Tue Jun 28 12:21:40 UTC 2016

I am WELL versed on what it is. The issue is why this is included at all.
Sent from my mobile. Please excuse brevity and typos.

On June 28, 2016 11:14:57 AM GMT+03:00, Rinalia Abdul Rahim <rinalia.abdulrahim at gmail.com> wrote:
>My understanding from Staff is that the RSEP is not a back door for
>domains. Cyrus Namazy can explain and I am copying him.
>Best regards,
>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
>> to Base New gTLD Registry Agreement"
>> https://community.icann.org/x/uBiOAw
>> Reading through the material that was made available, it appears that
>> 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
>> and in the "current" round of new gTLDs, this prohibition took place.
>> have checked with Julie Hammer, our SSAC Liaison, whether the SSAC
>> changed its advice since SAC053. She has assured me that this was NOT
>> case.
>> To summarize the concern, the proposed RA amendment creates a
>> path to approval of dotless domains using the RSEP process, which has
>> potential to circumvent the existing prohibition.
>> In further details:
>>    - On May 31, ICANN posted proposed amendments to the New gTLD
>>    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
>>    ALAC
>>    *,* 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
>>    voted
>>    to prohibit dotless domains.
>>    - The proposed New gTLD Registry Agreement (RA) amendments include
>>    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
>>    dotless domains via the Registry Services Evaluation Process
>(RSEP).  The
>>    relevant language is below:
>>    - (Note:  The above language effectively does not allow, among
>>       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
>>       Process (RSEP) request.  This will be evaluated per RSEP to
>>       whether the service would create a risk of a meaningful adverse
>impact on
>>       security or stability of the DNS.  Registry Operator recognizes
>>       acknowledges that a service based on the use of less-common DNS
>>       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
>>    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
>>    Board, IAB, SSAC, GAC or ALAC on this issue. Unlike the previously
>>    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
>>    appropriate policy work and/or community consideration.
>>    - Introduction of this proposed use of RSEP is inappropriate and
>>    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
>> advice has changed? This way, they would be able to respond to  the
>> record accordingly.
>> Kindest regards,
>> Olivier MJ Crépin-Leblond
>ALAC mailing list
>ALAC at atlarge-lists.icann.org
>At-Large Online: http://www.atlarge.icann.org
>ALAC Working Wiki:
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