FINAL VERSION TO BE SUBMITTED IF RATIFIED
FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC
No change from First Draft below
FIRST DRAFT SUBMITTED
The following Draft Statement is offered to trigger community comment and further input before finalization.
DRAFT ALAC STATEMENT ON
"MITIGATING THE RISK OF DNS NAMESPACE COLLISIONS":
A STUDY REPORT BY JAS GLOBAL ADVISORS ("JAS")
The ALAC welcomes the publication of the "Mitigating the Risk of DNS Namespace Collisions" study report by JAS Global Advisors but notes that at this stage, this report is incomplete. For security reasons, certain technical details have been omitted until vulnerabilities discovered during the study have been remedied.
The ALAC notes the assumption on page 3 that “The modalities, risks, and etiologies of the inevitable DNS namespace collisions in the new TLD namespaces will resemble the collisions that already occur routinely in other parts of the DNS.” While there is probably reasonable logic to make this assumption, only time will tell whether it proves to be valid.
The ALAC supports Recommendation 1 which proposes that the TLDs .corp, .home and .mail be permanently reserved for internal use, but considers that there are other potential TLD strings in high use in internal networks that should also be considered for reservation.
The ALAC considers that Recommendation 3 sets too high a barrier for the application of emergency response options. In deeming that these responses be limited to situations which present a “clear and present danger to human life”, this ignores a broad range of scenarios which may have huge detrimental impact on, for example, national security, critical infrastructure, key economic processes and the preservation of law and order. Indeed, a situation which presents a “probable danger to human life” should potentially be included. While recognizing the difficulty of making such judgments, the ALAC recommends that a more moderate approach be pursued in relation to emergency response options.
In conclusion, the ALAC reaffirms its view that security and stability should be paramount in the ongoing introduction of new TLDs and that the interests of internet users, whether they be registrants of domain names in the new TLDs or users who are impacted by disruption to the smooth operation of internal networks, should be safeguarded. ICANN should continue to implement initiatives to educate and inform not only system operators but also individual internet users.