[NCAP-Discuss] Report Changes Based on Public Comments

Fri Apr 5 19:53:36 UTC 2024

I agree with Jim on the second point but I would not use the word "enact"
as that is a legislative work.  the word should be "effect".

Anne Aikman-Scalese
GNSO Councilor
NomCom Non-Voting 2022-2024
anneicanngnso at gmail.com

On Fri, Apr 5, 2024 at 12:47 PM James Galvin <galvin at elistx.com> wrote:

> Thank you to Michael for his yeoman’s work getting us to here. I have
> given this document yet one more read and I am pleased to be able to
> support it being published.
>
> However, I do have two issues with the final text that I call out here.
> Perhaps our Chairs, if not Michael, could respond and help me to understand
> what I’m missing.
>
> 1. I deleted a sentence that I believe simply does not belong. I inserted
> bookmark at the sentence so folks can jump right there and see it:
> https://drive.google.com/drive/u/0/folders/1ailLZ63CG_p71FTQzc8ANJhnRgqR7H10
> .
>
> In fact, if you scroll from there you’ll see I deleted the same sentence
> from multiple recommendations, in part because they are out of context and
> also because they are not quite accurate. Once you get to Recommendation
> 5.9.1, you’ll see I added a comment that suggests that perhaps rather than
> deleting this sentence everywhere it can be rewritten to suggest that folks
> look forward to Rec 5.9.1. for details on managing the Collision String
> List.
>
> 2. Unless I’ve completely missed some discussion we had, I think the last
> paragraph in Recommendation 10 in Section 5.10 is backwards. Here’s a
> bookmark that takes you precisely to the paragraph:
> https://docs.google.com/document/d/1TO8uQf_17DwITy-jQUvPfDR9dcIk7nX_KLjjKQ0akcg/edit#bookmark=id.i7g1134p7tcy
> .
>
> You’ll see in my comment that what I believe happened is two separate
> responsibilities got conflated inappropriately. Specifically, it seems to
> me that the TRT expressly has the responsibility and the accountability to
> make sure that an emergency removal from the root zone happens if needed.
> It might make this decision itself or might be called upon to assess a
> request if it’s an external report. What the TRT does not have is the
> operational authority or responsibility to actual remove the string from
> the root zone. That is something that only IANA can do.
>
> I do not remember any discussion different than that. Can somebody point
> me at when this got flipped, or is this just an editorial oversight?
>
> Thanks,
>
> Jim
>
>
> On 3 Apr 2024, at 3:39, Michael Monarrez Puckett wrote:
>
> Hello all,
>
> Below are a summary of the changes made to the report based on last week's
> discussion of adopted changes based on public comments. Most of the changes
> are to make statements less direct using passive voice (rather than stating
> that the TRT should or that ICANN org must). These were the only items
> outstanding from changes to the report related to public comments. I will
> be amending the public comments Annex to account for adopted changes and to
> prepare that document for the final package.
>
> - Removed references to research about IPv6-only hosts being out of scope;
> Replaced with "IPv6 is a risk tradeoff which was thoroughly discussed in
> the JAS report. There is no clear, risk-free approach to 2012-style CI in
> v6 space." in Sec. 3.5.2 on CI
> - Specified that regarding the process for emergency changes to the root
> zone when considering the temporary delegation of strings, there is no
> "publicly documented" process in Finding 4.7
> - Removed references to ICANN org needing to provide sufficient resources
> for implementation quick like a bunny; Made statement more passive/general:
> "sufficient resources would be required for expeditious implementation."
> - Removed all references to future studies being necessary as the DNS
> evolves.
> - Removed references to TRT having responsibility for removing strings
> test-delegated to the root from the root upon their addition to the
> Collision String List; Made statement more passive/general by stating that
> there must be a process for doing so.
> - Removed reference to the TRT recommending time frames for the Name
> Collision Risk Assessment Framework; Made statement more passive/general:
> "time frames...should be distributed to the public as early as possible"
>
> Over the next three days, I will focus on non-material editing and
> additional necessary preparations to finalize all documents for delivery by
> this Friday, April 5. Should I find inconsistencies that require technical
> expertise, I will be sure to reach out to this group for guidance.
> Otherwise, I'm pleased to share that we are on track for delivery by the
> expected date.
>
> Thanks,
> Michael Monarrez Puckett
>
> On Thu, Mar 21, 2024 at 2:41 PM Michael Monarrez Puckett <
> monarrez4565 at gmail.com> wrote:
>
>> Hello all!
>>
>> tl;dr -- Action items:
>> - Review Annex: Public Comments Analysis
>> <https://docs.google.com/document/d/1QXc6giTfSRsfLtvxJjzrHzFT1aCPuJgALFVPWZUbVtw/edit>
>> - Review edits to draft report
>> <https://docs.google.com/document/d/1TO8uQf_17DwITy-jQUvPfDR9dcIk7nX_KLjjKQ0akcg/edit>
>> based on public comments
>> - See organized Final Report folder
>> <https://drive.google.com/drive/u/0/folders/1ailLZ63CG_p71FTQzc8ANJhnRgqR7H10>
>> in shared drive
>>
>> Thank you Matt Larson and Matt Thomas for your feedback on the public
>> comments Annex document. I've made updates to the responses to public
>> comments and the agreed-upon adoptions of edits to the report. Please see
>> the Annex and add comments with feedback as you see fit as this document
>> will be part of the final report package and contain responses on behalf of
>> the NCAP DG to each public comment.
>>
>> I've updated the report with the edits based on public comments. These
>> edits I've made in Suggesting mode. Please take the time between now and
>> next week's meeting to review changes to the report, add comments, or make
>> changes in Suggesting mode. Note that the changes are only in relation to
>> the DG's responses to public comments.
>>
>> I've created a folder in the shared drive titled "0 Final Draft," which
>> contains the edited draft report, the draft Board Questions document, and
>> the annex of public comments analysis. This folder is intended to organize
>> the documents that will be part of the final parcel delivered to SSAC:
>> https://drive.google.com/drive/u/0/folders/1ailLZ63CG_p71FTQzc8ANJhnRgqR7H10
>>
>>
>> If you have any questions, comments, concerns, or suggestions, please
>> take the time over the next week to make your voice heard so that we can
>> wrap up the Final Report in due time.
>>
>> Thank you,
>> Michael
>>
>> On Thu, Mar 21, 2024 at 5:01 AM Thomas, Matthew <mthomas at verisign.com>
>> wrote:
>>
>>> Michael,
>>>
>>>
>>>
>>> Thank you for putting this together.  I just reviewed and placed a few
>>> comments/suggest in the document.  Overall, I think this is in good shape;
>>> however ……
>>>
>>>
>>>
>>> @ALL-NCAP-DG – Please, please, please take some time to review and
>>> comment/suggest!  We are so close to the finish line.  Let’s get this done!
>>>
>>>
>>>
>>> Matt Thomas
>>>
>>>
>>>
>>> *From:* NCAP-Discuss <ncap-discuss-bounces at icann.org> on behalf of
>>> Michael Monarrez Puckett <monarrez4565 at gmail.com>
>>> *Date:* Tuesday, 19 March 2024 at 01:27
>>> *To:* "ncap-discuss at icann.org" <ncap-discuss at icann.org>
>>> *Subject:* [EXTERNAL] [NCAP-Discuss] Report Changes Based on Public
>>> Comments
>>>
>>>
>>>
>>> *Caution:* This email originated from outside the organization. Do not
>>> click links or open attachments unless you recognize the sender and know
>>> the content is safe.
>>>
>>> Hello team!
>>>
>>>
>>>
>>> Here’s a link to the completed Annex of public comments received, NCAP
>>> DG responses, and report changes adopted.
>>>
>>>
>>>
>>> Please review the responses in column 4 (NCAP DG Response) and leave a
>>> comment in the document should you have any concerns or suggestions.
>>>
>>>
>>> https://docs.google.com/document/d/1QXc6giTfSRsfLtvxJjzrHzFT1aCPuJgALFVPWZUbVtw/edit
>>>
>>>
>>>
>>> I’m currently in the process of editing the report based upon the DG’s
>>> responses to public comments. I will share those edits with the group as
>>> soon as possible—by tomorrow or Wednesday at the very latest.
>>>
>>>
>>>
>>> Having the report edits reviewed and approved (or else modified based on
>>> feedback) prior to next week’s meeting would be ideal.
>>>
>>>
>>>
>>> Thanks!
>>>
>>> Michael
>>>
>>> ———
>>>
>>>
>>>
>>> Focal points for report edits:
>>>
>>> - Operationalization of TRT and implementation of Name Collision Risk
>>> Assessment Framework should be expeditious, for which ICANN org would need
>>> to provide sufficient resources.
>>>
>>> - TRT should have the responsibility to remove a string from the String
>>> Collision List upon finding that the risk of collision has been
>>> appropriately mitigated.
>>>
>>> - All strings should be subject to a typical technical evaluation
>>> process without preferential review treatment for any grouping of strings.
>>> The implementation of special procedures for certain types of strings based
>>> upon policy adoption is out of scope for this report.
>>>
>>> - Further research by the ICANN community will be necessary based on
>>> evolutions in the DNS and name resolution issues.
>>>
>>> - The data collection methods proposed for the TRT are a small sampling
>>> of known and tested methods. Other methods may be used, but they remain
>>> untested and are out of scope within this report. Ultimately, which methods
>>> to use should be critically considered during the operationalization of the
>>> TRT.
>>>
>>> - The NCAP DG deliberated on the proposed data collection methods as a
>>> sample of possible and available methods based upon careful consideration
>>> and balance of data privacy risks and potential benefits.
>>>
>>> - Data that is presently available to the public, which applicants could
>>> use to self-assess their applications is constrained.
>>>
>>> - The data to be made publicly available to applicants should be
>>> recommended by the TRT during its implementation based upon critical focus
>>> of data sources that would strengthen applications.
>>>
>>> - The TRT should distribute time frames to the public as early as
>>> possible for stages of the Name Collision Risk Assessment Framework based
>>> on implementation details.
>>>
>>> - Updated the agreed-upon definition of “name collision” within the
>>> report based on the response from ICANN org.
>>>
>>> - The NCAP DG does not find it within its remit to provide specific
>>> guidance on elements of the operationalization of the Technical Review Team
>>> and the Name Collision Risk Assessment Framework, including what data to
>>> collect, how to assess this data, and how to maintain compliance with data
>>> privacy and risk management standards. The intent of not prescribing
>>> implementation details is for ICANN org to have broadly lateral oversight.
>>>
>>> - The ICANN org would need to implement a data privacy and protection
>>> policy, along with appropriate risk mitigation measures for legal
>>> compliance.
>>>
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