[IDN-WG] ALAC Statement on the Label Generation Rules for the Root Zone - Second Public Comment Draft

[JJS]

*Dear Rinalia & Edmon,*
*very good draft!*
*I've inserted 2 small points on the wiki.*
*Jean-Jacques.
*
2013/1/8 Rinalia Abdul Rahim <rinalia.abdulrahim at gmail.com>

> Dear ALAC and IDN WG,
>
> Edmon and I have prepared a draft statement in response to: At-Large IDN
> Variant TLD Program – Procedure to Develop
> <https://community.icann.org/x/7YxEAg>and
> Maintain the Label Generation Rules for the Root Zone in Respect of IDNA
> Labels – Second Public Comment Draft
> Workspace<https://community.icann.org/x/7YxEAg>
> ?
>
> Please provide your comments on the wiki so that all input are captured in
> one place.  The link above will take you to the wiki as well as this one -
> https://community.icann.org/pages/viewpage.action?pageId=38046957.
>
> Text pasted below for your information.
>
> Best regards,
>
> Rinalia
>
> DRAFT 8 Jan 2013
>
> *ALAC Statement on the IDN Variant TLD Program – Procedure to Develop and
> Maintain the Label Generation Rules for the Root Zone in Respect of IDNA
> Labels – Second Public Comment Draft*
>
>
>
> *Acknowledgment of Project 2.1 Team Achievement***
>
>
> The At-Large Advisory Committee (ALAC) commends the IDN Variant TLD Program
> Project 2.1 Team for its efforts and contributions in establishing vital
> procedures that will enable the delegation and management of IDN Variant
> TLDs toward enhancing multilingualism and cultural diversity on the
> Internet.
>
> We appreciate the Project Team’s openness to input and we are pleased to
> see the incorporation of some of our suggestions in the revised “Procedure
> to Develop and Maintain the Label Generation Rules for the Root Zone in
> Respect of IDNA Labels.”**
>
>
>
> *The 2-Panel Process and Effective Outreach*
>
> *
> *
>
> We reiterate our support for the 2-panel process in the development of the
> Label Generation Rules for the root zone, which allows different IDN
> language and script communities to form and move at their own pace in
> implementing IDN Variant TLDs.
>
>
>
> For effective outreach to various language and script communities that may
> be interested in forming Generation Panels, we call on ICANN to ensure that
> all announcements and reports related to the implementation of IDN Variant
> TLD be published in multiple languages, particularly the languages
> addressed by the Variant Case Studies and the ones recommended for
> prioritization in the Procedure Document.**
>
>
>
> *Limited Supply of Global Experts for the Integration Panel*
>
> *
> *
>
> We note with concern that the supply of experts for the Integration Panel
> is limited.  This limitation is problematic for the following reasons: (a)
> It makes it challenging to ensure diverse cultural backgrounds among the
> panel members; (b) It places the continuity of the Label Generation Rules
> process at risk where communities that enter the process late may be
> affected adversely; (c) It allows for the possibility of process capture by
> a few experts.
>
>
>
> We urge ICANN to ensure the sustainability of the Label Generation Rules
> process for the global language and script communities, who are at
> different levels of readiness to develop Label Generation Rules for their
> specific script, writing system and language.  We recommend that ICANN
> undertake strategies to secure a steady supply of expertise (which may
> include the provision of appropriate incentives as well as capacity
> building) while placing appropriate term limits that safeguard the process
> against capture.
>
>
>
> *Governance Oversight and the Public Comments Process*
>
> *
> *
>
> We recognize that the Integration Panel requires independence to carry out
> its task.  We wish to stress that this independence needs to be accompanied
> with high standards of transparency and strong accountability measures.
>  The
> Procedure Document specifies the ICANN Public Comments as the primary
> governance oversight mechanism for the decisions of the Integration
> Panel.  This
> mechanism has certain weaknesses: (1) It has no review process; (2) It does
> not include an appeal process for the decisions of the Integration Panel;
> and (3) The challenges associated with the Public Comments process still
> apply (e.g., participation of relevant stakeholders, sufficient comment
> period, etc.).  It is imperative that ICANN address the weaknesses of the
> proposed mechanism to support a transparent and accountable process of
> developing Label Generation Rules for the root.
>
>
>
> The Procedure Document points out the following: “There is an argument that
> could be made that the population of the root LGR is making policy. In
> which case, the current policy-making procedures in the ccNSO and gNSO
> could be used.”  Unless there is a compelling reason as to why the Label
> Generation Rules process should be independent of the oversight mechanisms
> of the ICANN Supporting Organizations (SOs), the ALAC advises the ICANN
> Board to authorize the respective SOs (i.e., GNSO and ccNSO) to oversee the
> implementation of the proposed mechanism.  The appropriate governance
> oversight measures should include periodic reviews, high standards of
> transparency and accountability structures worthy of the ICANN bottom-up
> multi-stakeholder model.  Furthermore, special emphasis on the effective
> engagement and participation of affected linguistic communities would be
> crucial throughout the LGR process.
>
>
>
> *Enabling Policies*
>
>
>
> Given the prioritization of IDNs in the new gTLD process, the ALAC strongly
> advises the ICANN board and community to begin addressing the policies
> required to render the procedures for IDN Variant TLD delegation
> operational on an urgent basis.  Statistics from the Interim Report of the
> IDN Program Project 6 on User Experience highlights that almost 20% of user
> queries could be directed towards an IDN Variant TLD.  This means that
> without the delegation of the IDN Variant TLD, almost 20% of users would
> have a negative experience.  Without having the requisite enabling policies
> in place to support the roll out of the new gTLDs, the prioritization of
> IDNs would in fact significantly hurt consumer trust and serve as a
> disservice to the IDN community.
>
>
>
> *Communicating Convergence Effectively*
>
> The Procedure Document indicates that, “the mechanism is not the last stage
> in making determinations about IDN labels for the root. Rather, its output
> is to be consumed by other ICANN procedures that actually determine whether
> a particular label is allocated to someone, and whether it is delegated in
> the root.”  We request that ICANN clarify how the various procedures and
> processes interface, interact or converge against an estimated timeline for
> the benefit of the community.
>
>
> END
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>
> IDN WG Wiki:
> https://community.icann.org/display/atlarge/At-Large+IDN+Policy
>