[ispcp] ISP and Connectivity Provider (ISPCP) constituency comments on ICANN's proposal to mitigate name collision risks

[Mike O'Connor]

Dear ICANN,

The Internet Service Providers and Connectivity Providers constituency (ISPCP) respectfully submits the following comments on ICANN's August 5 Proposal to Mitigate Name Collision Risks.

We are available to respond to any questions or comments.

Best regards,

Mike O'Connor -- ISPCP Rapporteur 

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ISPCP Comment

Whereas: the potential for name collision may be substantial

Whereas: the potential for name collision often arises from well-established policies and practices in private network environments

Whereas: the risk associated with delegating a new TLD label arises from the potentially harmful consequences of name collision, not the collision itself

Whereas: name collision in general may threaten the assumption that an identifier containing a DNS domain name will always point to the same thing

Whereas: the opportunity for X.509 public key certificates to be erroneously accepted as valid is an especially troubling consequence of name collision

Whereas: designation of any applied-for string as “high risk” or “low risk” with respect to delegation as a new gTLD depends on both policy and analysis -- activities which have not yet been completed

Whereas: the analysis to evaluate the nature and impact of name-collision risk has not been completed

Whereas: corporations, ISPs and connectivity providers may bear the brunt of the security and customer-experience issues resulting from adverse (as yet un-analyzed) impacts from name collision

Whereas: those same corporations are in large part not active participants in the ICANN community and are only just becoming aware of these issues

Whereas: these issues, due to their security and customer-experience aspects, fall outside the remit of people who normally participate in the ICANN process, requiring extensive wide-ranging briefings even in corporations that do participate actively in the ICANN process

Therefore, the ISPCP requests the following.

-- that ICANN complete further study of name-collision issues to understand their nature and impact, following the recommendations made in the InterIsle report
 
-- That the initial public comment period be placed on hold until such a study is completed, or if that is deemed infeasible, at least extended for 60 days to allow a more detailed assessment of the important issues raised