[IDN-WG] Fwd: Draft Comments on the Draft Implementation Plan for IDN ccTLDs 3rd Revision.

[Sivasubramanian Muthusamy]

Hello,

A draft comment on the 3rd revision of the "Draft Implementation plan for
IDN ccTLDs" is forwarded to this working group for additions and comments.

Please comment.

Thank you
Sivasubramanian Muthusamy
IDN liaision.


---------- Forwarded message ----------
From: Sivasubramanian Muthusamy <isolatedn at gmail.com>
Date: Sat, Jun 27, 2009 at 5:10 AM
Subject: Draft Comments on the Draft Implementation Plan for IDN ccTLDs 3rd
Revision.
To: ALAC Internal List <alac-internal at atlarge-lists.icann.org>
Cc: At-Large Staff <staff at alac.icann.org>


ALAC Comments on Draft Implementation Plan for IDN ccTLD Fast Track Process
Revision 3

Posted as an initial draft to start the comment process. The red line
(actually it is in blue color) version of the 3rd revision of the draft
implementation plan is attached to show changes

During the ICANN meeting at Mexico, the ICANN Board encouraged the community
to continue its work so that the implementation plan can be finalized and
considered by the Board no later than at its annual meeting in 2009.

ICANN has released the third revision of the Draft Implementation Plan for
IDN ccTLDs.
A public comment on this plan and the related papers is due on 15th July.
Comments received will be used to revise the plan in preparation of a Final
Implementation Plan which is expected to be provided for Board consideration
no later than at the ICANN meeting in Seoul, 25-30 October 2009


   1. In this revision detailed explanations of the entire evaluation
   process have been included together with flowcharts which points for clarity
   of expression and further progress towards implementation. ALAC notes these
   details in the Implementation plan as a sign that IDN TLDs are moving closer
   to implementation.
   2. ALAC in agreement in principle that “the request for an IDN ccTLD
   cannot proceed through the Fast Track Process if the Panel or review team
   identifies that a requested string raises significant security and stability
   issues” ( 4.1)
   3. In line with the IDNC WG Final Report, the external and independent
   DNS Stability Panel should be appointed to conduct technical due diligence
   and report to the ICANN Board. And in agreement with the IDNC WG report, the
   3rd revision excludes the reference to the Registry Services Evaluation
   Process and the hint of DNSSEC but instead adds that “ICANN will secure the
   services of a competent technical panel (DNS Stability Panel) to make
   stability evaluations” And the report adds that “ICANN is finalizing the
   coordination of the DNS Stability panel and further details will be made
   available”. ALAC awaits further details.
   4. The 3rd revision further enhances the role of Governments in the IDN
   ccTLD application process with its emphasis on “evidence of support” and the
   deletion of [evidenced of] “non-objection” as documentation requirements in
   the Preparation Stage. As in previous drafts, the 3 rd revision retains its
   position that such evidence of support needs to be from “the Minister with
   the portfolio responsible for domain name administration, ICT, foreign
   affairs or Office of the Prime Minister or President; or a senior
   representative of the agency or department responsible for domain name
   administration, ICT, Foreign Affairs or the Office of the Prime Minister.”
   While this stipulation reflects the positive involvement of Governments in
   the IDN TLD process and their concerns,  and is in tune with ICANN's ccTLD
   delegation policies, ALAC notes with apprehension that International Domain
   Names as ccTLDs, together with ascii ccTLDs could enable governments to
   control access and curtail civil liberties. ALAC expresses concern about the
   emphatic reference to Governments which in effect makes the Governments as
   the requesters, either directly or indirectly. The description of the
   Preparation Stage process ( 5.1.1) specifies 1) 1. Support from the relevant
   government or public authority 2) Support ... by the relevant government,
   ALAC expresses concerns on this continued and emphatic references to
   Governments as total deviation from the gTLD processes and principles.
   5. ALAC is committed to multi-stakeholder approach and notes postively
   the inclusion of the passage “The application should demonstrate there has
   been community dialogue regarding which string is the appropriate
   representation of the country in the selected string(s) and/or
   language(s)/script(s), and that appropriate stakeholders have been involved
   in the decision making process.” and feels that this passage alone could
   address the concerns of Governments and all stakeholders.
   6. Alac welcomes the proposed submission system for the string evaluation
   stage (Stage 2) as a web-based form that identifies the information
   necessary. ALAC feels that web based processes would be of help in enabling
   swift submission of the required information and would lead to transparency
   even in the level of applications as submitted.
   7. ALAC notes that the 3rd revision excludes portions of Module 7 of the
   2nd revision purportedly "to only contain discussions of outstanding
   issues". Topics deleted from the previous versions of the plan are
   “considered solved” though included elsewhere in the plan “as deemed
   necessary”. Module 7: Discussion of Additional Topics has been entirely
   deleted in the third revision with the observation that “most of the topics
   remaining in this module relate directly to the overarching requirements to
   Preserve the security and stability of the DNS and Ensure compliance with
   the IDNA protocol and IDN Guidelines.The remaining topics included have all
   been addressed in supporting papers to this plan. (But the hypertext links
   to the documents are not included in the draft implementation Plan
   document.) Alac wishes to comment that the topics could have been listed
   under a separate section of the report as topics considered solved to retain
   the extent and depth of topics related to the IDN TLD process.
   8. ALAC feels that the topic of “Financial Contribution” or cost
   recovery, for instance could not be considered as a topic that can be
   “considered solved”. ALAC feels that more discussions are needed on the
   details of the proposed cost recovery model.

Sivasubramanian Muthusamy

ALAC IDN liaison.
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