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

Rinalia Abdul Rahim rinalia.abdulrahim at gmail.com
Tue Jun 28 13:07:40 UTC 2016

I was in the session when this was discussed today on base
Registry agreement. Verisign raised the same concern about Exhibit A and
proposed that dotless domains be placed under section 2.2 on items

Staff explanation was that the listing of items under exhibit A is based on
a pre-existing list of items and that inclusion doesn't translate
into automatic approval.

I think staff got a clear message from the meeting that this is something
they need to address and fix.


On Tuesday, 28 June 2016, Alan Greenberg <alan.greenberg at mcgill.ca> wrote:

> 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
> <javascript:_e(%7B%7D,'cvml','rinalia.abdulrahim at gmail.com');>> wrote:
>> 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
>> <javascript:_e(%7B%7D,'cvml','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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