[ALAC] Proposed Amendments to Base New gTLD Registry Agreement Workspace
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.
>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"
>> 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
>> 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
>> 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
>> closes on July 13 and there is a cross-community session scheduled
>> 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
>> new gTLDs.
>> - In August 2013, the ICANN Board’s New gTLD Program Committee
>> to prohibit dotless domains.
>> - The proposed New gTLD Registry Agreement (RA) amendments include
>> change in Exhibit A (Approved Services) related to dotless
>> 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
>> relevant language is below:
>> - (Note: The above language effectively does not allow, among
>> things, the inclusion of DNS resource records that would enable
>> domain name (e.g., apex A, AAAA, MX records) in the TLD zone.)
>> 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
>> 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
>> 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.
>> 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
>> the significant security and stability concerns raised by the IAB
>> dotless domains should instead receive the same treatment in the
>> 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
>> 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
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