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The final draft version to be voted upon by the ALAC will be placed here before the vote is to begin.

FIRST DRAFT SUBMITTED

The ALAC congratulates the ccNSO Framework of Interpretation Working Group (FOIWG) on its work to clarify the parameters governing the revocation of ccTLD delegation by the IANA Operator.

Clarity on the revocation parameters and process is crucial to ensure that any act of revocation on the part of the IANA operator is carried out with sensitivity and care, as a last resort, and does not in any way disrupt the continued name resolution for Internet users.

The ALAC agrees with the Working Group’s interpretation of RFC 1591, which provides for revocation as one of three mechanisms available to the IANA Operator.  We support the selected limits of revocation to cases where there are “persistent problems with the operations of the domain” and where there continues to be “substantial misbehavior” on the part of ccTLD managers despite the IANA Operator’s best efforts to stop the misconduct.  We are also satisfied that the Working Group has defined what constitutes “persistent problems” and “substantial misbehavior” clearly to support appropriate action by the IANA Operator.

In section 2.2.2 of its report, the Working Group indicated that it had considered whether the GAC Principles and accompanying guidelines are consistent with the RFC 1591 and whether they provide an aid to the Working Group’s interpretation.  We do not see any conclusion to these considerations.  However, we do note that section 4.3.7.2 appears to factor the GAC Principles in specifying that “If the IANA Operator revokes a delegation it should attempt, in collaboration with the significantly interested parties to ensure the ccTLD will continue to resolve names until a suitable replacement can take over.”

We further suggest the following to strengthen the interpretation work:

1. Specify further the appeals mechanism for the ccTLD manager in the case of revocation in section 4.3.7.3.  Operationalization of the interpretation would be more efficient if there is more clarity on the type and geographic jurisdiction of the “independent body” that would qualify for the appeals process.
2. Request the IANA to maintain accurate and informative reports on cases of re-delegation and to record receipts of delegation transfer consent from the incumbent ccTLD manager so as to better distinguish clear revocation cases when reviewing the IANA’s performance.

With regard to the questions posed by the FOIWG to the community, our responses are as follows:

1. Is the approach used by the working group satisfactory?

Yes.

1. Do the issues identified by the working group for this topic capture the major problems associated with the topic? If not what is missing?

Largely yes.  See the ALAC’s comment in the section above for gaps.

1. Is the proposed interpretation of the relevant sections of RFC 1591 effective and supported?

Yes.

1. Are the proposed recommendations effective in addressing the concerns raised in the final report of the DRDWG regarding this topic?

Yes first draft submitted will be placed here before the call for comments begins.