[Accred-Model] Comment - Alan Greenberg

[Alan Greenberg]

This comment has been circulated within the ALAC and At-Large, but 
there has not been sufficient time to decide to what extent if it 
fully accepted. As such, it is being submitted here purely on my 
personal behalf.

===============

There has been significant community comment that this proposal was 
originally (and to some extent still is) a creature of the BC.

I APPLAUD that the BC/IPC have taken the initiative to do this! I and 
many of us have been saying for several months (certainly starting 
before the Abu Dhabi meeting) that the accreditation model is an 
absolute key to moving forward.

The BC/IPC have done something and put it down on paper. Bravo!

I think this model is a great start.

I see problems with it, but we need to start the discussion 
somewhere. What do I see as problematic?
    * I think the provision to give access to "All users", while it 
would be nice for me personally, is more than a bit loose. We are 
going to need something MUCH stronger to grant access over and above 
the other accredited channels.
    * A single tier is not sufficient. There should be more 
granularity based on the uses. Perhaps we could start with this 
single and improve later, but my preference would be to use the 
use-cases we have already built to provide more than one few tier (ie 
more than just a) thin WHOIS, or b) ALL of the data.)
    * I look forward to the work that the document says the SSAC is 
doing regarding credentialization.
    * I STRONGLY support the 
<https://community.icann.org/download/attachments/84213851/APWG-GDPR-Accreditationplancomments-5April2018-0001.pdf?version=1&modificationDate=1524004586000&api=v2>comments 
from the Anti-Phishing Working Group (APWG). These comments make the 
model more effective and implementable. The only one I find possible 
questionable related to funding the accreditation process. Although I 
would prefer that it is an integral part of the DNS and WHOIS (and 
thus funded by ICANN through its normal sources), I would not want to 
see implementation delayed over this issue.
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