|Date Submitted to ICANN Public Comment|
|Comment: Proposed Renewal of .asia Registry Agreement|
The ALAC supports the proposed changes to the .asia (DotAsia) renewal agreement, with (3) comments related to universal acceptance (UA), public interest commitments and fees to be paid to ICANN org.
|Comment: ALAC Statement on Registry Agreement Renewals .org, .biz and .info|
The ALAC generally refrained from commenting on these prior proposed Registry Agreement renewals, with the exception of the proposed renewal of the .NET Registry Agreement in 2017. The ALAC in general favors standardizing Registry Agreements as this allows for transparency and predictability, as well as ease of review and compliance monitoring of one standard contract (with necessary but controlled variations through Addendums) instead of managing many disparate/varying contracts. Being supportive of this approach, the ALAC has not objected to the base Registry Agreement, or to its use in prior renewals.
In respect of the intent to standardize the said 3 proposed Registry Agreement renewals (.org, .biz, .info), the ALAC welcomes the following proposals:
(i) inclusion of Public Interest Commitments (per Specification 11),
The ALAC also noted there are differences in opinion within At-Large regarding the omission and quantum of price caps.
|Advice (sent to ICANN Board): GNSO Expedited Policy Development Process (EPDP) on the Temporary Specification for gTLD Registration Data Policy Recommendations for ICANN Board Consideration|
The ALAC provided advice to the ICANN Board, noting significant concern related to three aspects of the EPDP Report. Specifically, the ALAC is concerned not only with the outcomes, but with the process that was followed to address the issues. All three impact the ability to access registration data and the completeness of that data, specifically: “to identify the appropriate balance for a path forward to ensure compliance with the GDPR while maintaining the existing WHOIS system to the greatest extent possible”. The ALAC advises the ICANN Board to:
|Comment (sent to ICANN Board): ICANN64 Joint GAC-ALAC Statement on EPDP|
During ICANN64, the At-Large Advisory Committee (ALAC) and Governmental Advisory Committee (GAC) drafted and approved a Joint GAC-ALAC Statement on the EPDP. The GAC and ALAC are aligned overall with the EPDP Phase I Report, as it pertains to outstanding concerns as articulated in their respective statements to the report. The two advisory committees are in agreement on the need to distinguish between natural and legal persons. In addition, the GAC and ALAC highlighted the importance of data accuracy, the technical contact field, and protecting the public interest. The statement was drafted jointly with the GAC with input from the ALAC Liaison to the GAC, Yrjö Lansipuro, and GAC representative, Cathrin Bauer-Bulst, as well as the At-Large representatives to the EPDP, Hadia Elminiawi and Alan Greenberg.
|It is the view of the ALAC that the level of specificity for specific reviews is necessary to prevent misunderstandings and missteps by any of the parties involved in the review. The ALAC believes scope should be well defined within the confines of bylaws and review teams should be free to pursue their mandate within that scope. Accordingly, the ALAC voiced their strong support for the updates to the Operating Standards for Specific Reviews.|
|Comment: First Consultation on a 2-Year Planning Process||The ALAC/At-Large community agrees that more time should be given for additional community involvement, and requests that ICANN Org provide a listing of priorities and statements on the impact of each project within ICANN Org and on each of the unique ACs and SOs. The ALAC also encourages ICANN Org to provide the appropriate level of resources to ICANN IT for continued support of services which are vital for community policy work. The ALAC believes that the additional time from 15 months to 2 years would provide more transparency as the community is becomes more aware of priority ranking of projects or has collaborated with ICANN Org on priority ranking. The At-Large Advisory Committee believes that beyond the priorities of keeping the Internet secure and stable, and maintaining the multistakeholder model, the community should be directly involved in setting other priorities. In addition to policy activity, the ALAC emphasizes that outreach and engagement are integral to the planning cycle, and the benefit of CCWGs and CCEGs in planning activities. The ALAC supports a formalized, dedicated planning phase to plan for SO/AC activities. The ALAC noted it strongly believes that for ICANN to be as inclusive as possible, documents should be translated into multiple languages; important community meetings should be held in different time zones and in different languages, with real time translation (language channels) and captioning / real time transcription (RTT) provided on all calls. Finally, the ALAC strongly believes that for ICANN to be seen to be truly multistakeholder-focused and inclusive, then appropriate resources must be made available to remove barriers that might prevent the full participation of the ICANN community in policy activities.|
|Comment: ICANN Strategic Plan for Fiscal Years 2021 – 2025|
The ALAC stressed the importance of ICANN’s role in the multistakeholder model of Internet Governance (including 6 recommendations to improve its effectiveness), suggested a rebalancing of representation on the ICANN Board to enhance the Internet end user perspective, and noted that more fulsome cost/benefit analyses of programs like the gTLD expansion should be available in order predict the future impact on total resources. The ALAC also commented on strengthening the security of the Domain Name System (DNS) and the DNS Root Server System, evolving the unique identifier systems to continue to serve the needs of the global Internet user base, addressing geopolitical issues impacting ICANN’s mission to ensure a single and globally interoperable Internet, and ensuring ICANN’s long-term financial sustainability.
|1st Comment: ICANN Draft FY20 Operating Plan and Budget and Five-Year Operating Plan Update||Of principle concern to the ALAC/At-Large is their ability to achieve the objectives of the At-Large Review Implementation Plan. The comments in the statement relate to particular portfolio or project areas and incorporate specific At-Large concerns, namely: language services, raising stakeholder awareness of ICANN worldwide, engage stakeholders regionally, support policy development, policy related and advisory activities, reinforce stakeholder effectiveness, collaboration and communication capabilities, coordination of ICANN participation in Internet Governance, supporting organizational reviews, and supporting stakeholder participation.|
|2nd Comment:ICANN Draft FY20 Operating Plan and Budget and Five-Year Operating Plan Update|
The ALAC Chair determined to submit an additional ALAC statement on this public comment, in accordance with new rules regarding FY20 Additional Budget Requests (ABRs). As ABRs are no longer intended to request travel support to ICANN meetings, the ALAC decided to submit an additional comment to the FY20 Budget public comment, requesting two travel slots to support the attendance of active At-Large policy/outreach leaders in At-Large work session activities at ICANN meetings.
The ALAC notes that there has yet to be a discussion about whether any new gTLDs are needed. In case of an expansion, first and foremost, (1) strings with geographic connotations should not present harm (eg. risk for confusion) to end-users and (2) end-users, as residents of a given geographic entity, should have a say, through their governments or public authorities, in how its name is used. The ALAC prefers preventative protection mechanisms for country, territory, sub-national place and capital names. In the case of non-capital city names, there is a balanced support within the ALAC for either (1) requiring support or a non-objection letter from the relevant authority only if the applicant intends to use the TLD primarily for purposes associated with the city or (2) requiring support or a non-objection letter in any case. As to the 2012 AGB, ALAC thinks that its final version generally worked well and supports, in general, its treatment of geographic names.
|Comment:Application for New Uniform Domain Name Dispute Resolution Policy (UDRP) Dispute-Resolution Service Provider||The ALAC strongly supports the proposal for a new UDRP Dispute Resolution Provider, viewing it beneficial to the interests of all Internet end users, particularly to domain name registrants.|
|Comment: Initial Report of the Expedited Policy Development Process (EPDP) on the Temporary Specification for gTLD Registration Data Team||The ALAC submitted a Word Doc form mirroring the new Google Form requested by the EPDP Team for collection of this public comment. In its statement, the ALAC provided its answers on the questions posed by the EPDP Team. In particular, the ALAC made recommendations on additional purposes for processing registration data, including the Accuracy Reporting System (ARS) and research and threats analysis/prevention from the Office of the Chief Technology Officer (OCTO). Regarding data elements, the ALAC noted Registrant provided data must not be unilaterally removed without due consultation with the data provider, and the registrant must declare whether it is a natural or legal person. The ALAC noted the technical contact fields must be mandatory, and the Organization field should not be redacted. The ALAC also noted in its conclusion the SSAC revised version of SAC101, a paper previously supported by ALAC, drawing particular attention to the statement, "RDDS access must comply with the law, but access should not be less timely, more restricted and less public than law requires."|
|Comment: Supplemental Initial Report on the New gTLD Subsequent Procedures Policy Development Process (Overarching Issues & Work Tracks 1-4)||The ALAC put on record their responses, suggestions and in some cases, advocacy, to the preliminary recommendations, options and questions in the Report. In particular, the ALAC strongly opposes the retention of the regular highest-bid auction process which was used in the 2012 round (“regular auctions”) as the mechanism of last resort for resolution of contention sets within the Program, proposing instead that the ICANN Community explore the introduction of a multiplier-enhanced Vickrey auction, while supporting ways to increase avenues for voluntary resolutions of contention sets in order to avoid auctions. The ALAC also notably does not support a total ban of all forms of private resolutions, but are strongly in favor of disallowing forms of private resolutions which result in a ‘losing’ applicant gaining or being promised a financial benefit in return for withdrawing their application in a contention set, including and especially private auctions.|
|Comment: Proposed Consensus Policy on Protections for Certain Red Cross and Red Crescent Names in All Generic Top-Level Domains||The ALAC continues to take the position that as a humanitarian organization, and one that has been regularly the target of those seeking to fraudulently attract donations, the Red Cross should be afforded the courtesy of having its various identifiers protected at the second level in gTLD domain names. The ALAC cited its June 2018 statement of support for the Initial Report on the Protections for Certain Red Cross Names in all gTLDs – Policy Amendment Process, and affirmed support for the Reconvened WG's recommendations on proposed amendments.|
|Comment: Competition, Consumer Trust, and Consumer Choice Review Team (CCT) Final Report & Recommendations||As the principal voice of Internet end users within the ICANN community, the ALAC were interested in the findings and recommendations from the CCT Review, particularly in the areas of Choice and Trust. The ALAC is supportive of all of the recommendations in the Report, including the new ones relating to DNS abuse in New gTLDs. The ALAC reiterated they do not share a sense of urgency when it comes to subsequent procedures, but instead believe the community should address all of the deficiencies in the 2012 program before accepting additional applications. The ALAC commented on additional sections of the Report and Recommendations, including Recommendations 1, 8-10, 11-13, 14-25, 29-31, 32, 33 and 34-35.|
|Comment: Initial Report of the New gTLD Auction Proceeds Cross-Community Working Group||The ALAC have been following this issue closely, and discussed the issues internally prior to the issuance of the Initial Report. The ALAC discussed each of these mechanisms among the participants and members of the working group, and in their statement commented on Recommendations 1-10, noting it believes strongly that At-Large Structures (ALSes) and Individual members should be able to apply for funds; the proceeds from past auctions were intended for use in capacity building activities enhancing the mission of ICANN and consistent with one of its core principles for an “open and interoperable Internet”, for the benefit of the Internet community.|
|Comment: Draft Final Report of the Security and Stability Advisory Committee Review (SSAC2)||The ALAC is in support of the SSAC’s continued role in the ICANN community as an Advisory Committee. It commented specifically on Recommendations 1-5, 8, 10, 12, 14, 16-17, 21-22, 24 and 25 in the Report, noting that the SSAC should, in addition to revising its advice to the Board, also simultaneously attempt to write advice in such a way that non-technical experts in the ICANN community more easily understand them.|
|Comment: Registration Directory Service (RDS-WHOIS2) Review Team Draft Report of Recommendations||The primary concern for the ALAC in the RDS-WHOIS2 Review is the accuracy of registrant data (WHOIS data) and its use by security and law enforcement bodies in addressing the misuse and abuse of the DNS system. The ALAC summarized their positions on the 16 Recommendations under Objective 1, as well as Objectives 3, 5, 6 and the ICANN Bylaws.|
|Comment: ICANN Seeking Community Feedback on Proposed Unified Access Model||The ALAC cited their prior statement from 10 April 2018 relating to the access of WHOIS, and offered (4) general comments on the proposed UAM: (1) Any access model must be compliant with the GDPR, and ICANN should obtain legal advice from expert counsel to confirm compliance; (2) Internet end user rights should be part of the calculus, including knowledge of email sender identity, et al; (3) The UAM design should be scalable and not overly-reliant upon manual updates, and should have a well-defined taxonomy of abuse types, et al. Once an agreed upon set of inputs and outcomes is established, an automated system may be created to respond to WHOIS requests; (4) The various harms taken into account when considering the UAM must be done so in a non-biased fashion.|
|Comment: Draft PTI and IANA FY20 Operating Plan and Budgets||After consultations with the ICANN Finance Department and ALAC Finance and Budget Subcommittee (FBSC), the ALAC submitted comment on (4) sections of the Draft PTI and IANA FY20 Operating Plan and Budgets, including the Executive Summary, PTI Services Financial Overview, PTI Services Overview and PTI Services and Operating Plan.|
Note: submitted to ICANN Board as ALAC Advice; ratified during ICANN63.
|In its follow up to the joint statement, the ALAC and GAC agreed in the context of the Information Transparency Initiative (ITI) that clear and up-to-date information (from ICANN) to facilitate quick understanding of relevant issues and high interest topics is key for inclusive, informed and meaningful participation by all stakeholders, including non-experts – as, in the context of the IANA transition process – ICANN was able to offer timely and comprehensible information by breaking down complex issues into understandable components, which allowed interaction within the entire community. The ALAC and the GAC ask from ICANN that the same level of effort be made and the same service be provided to the community concerning information on all other relevant issues.|
|Comment: Proposed gTLD-Registration Data Access Protocol (RDAP) Profile||The ALAC recommends that ICANN adopt the RDAP quickly and effectively because they hold it is an essential step for ICANN to deploy a tiered-access model adequately. In addition, the ALAC recommends that ICANN address 5 ambiguities in the RDAP that are also present in the European Union's (EU) General Data Protection Regulation (GDPR), noting them in the statement.|
|Comment: Next Steps on Reviews||The ALAC supports the proposed path forward for the ATRT3, while stating the consideration of how to streamline specific reviews to make them more effective and impactful is a low priority item for ATRT3. The ALAC encourages active community participation in formulating any recommendations in organizational reviews, and states that specific reviews operating standards should take a minimalist approach.|
|Comment: Initial Report on the New gTLD Subsequent Procedures Policy Development Process (Overarching Issues & Work Tracks 1-4)||While the ALAC and wider At-Large community continue to debate the actual benefits to communities in expanding the New gTLD Program, they acknowledge that the Program will likely continue to be expanded in one form or another. In this respect, the ALAC put on record their responses, suggestions and in some cases, advocacy, to the preliminary recommendations and questions as posed by the GNSO New gTLD Subsequent Procedures PDP Working Group in its Initial Report, from the perspective of and benefit to Internet end users At-Large. The ALAC highlighted key consensus positions on the 86-page statement, including: Concept of "Rounds", Community Applications and Community Priority Evaluation, Metrics, Public Interest Commitments, Applicant Support Program, IDNs, Universal Acceptance, SSAC Research and Recommendations, Objections, and High Standards for Applicants.|
|Comment: Recommendations for Managing IDN Variant Top-Level Domains||The ALAC believes the main challenge while integrating IDN variant top-level domains is to balance positive user experience while ensuring the security, stability and manageability of the DNS. The ALAC provided advice on (4) questions posed by ICANN regarding the issue, and in general believes strict adherence to the Root Zone LGRs are the most appropriate way of arriving at IDN variant labels.|
|Comment: Draft ICANN Africa Strategic Plan 2016-2020 Version 3.0||The ALAC recommended (1) an increased number of African ICANN staff to be seriously considered in the Draft Africa Strategic Plan; (2) involving more African participation in strategy planning and implementation; (3) local capacity building; (4) increased representation of African stakeholders in the SOs and ACs in addition to the ALAC and GAC. The ALAC also noted criteria for implementation should be further developed, and offered collaboration with the African community in At-Large.|
Note: Not a formal ICANN Public Comment.
|The ALAC understands that tiered access is the most probable solution to ensuring compliance with the General Data Protection Regulation (GDPR), yet it has serious concerns as to the structure of this proposed model. The ALAC recommends a three-dimensional access model of accreditation: 1) identity of the petitioner; 2) determining the petitioner’s purpose; and 3) requesting information on how they will use that data. The ALAC feels these considerations towards the access model will propel the ICANN community further towards a reliable and trusted domain name system (DNS).|
|Comment:Open Data Initiative Datasets and Metadata||The ALAC made specific comments in relation to: (1) Centralized, easy access to properly organized data repository, (2) Types and value of data collected, lack of discernable information; (3) Uniformity of and responsibility for data; and (4) Privacy rights. Overall, the ALAC believes it would be useful if ICANN Org could assist in re-generating a list of datasets with suggestions on what downstream or upstream information can possibly be gleaned from each dataset.|
|Comment: Initial Report on the Protections for Certain Red Cross Names in all gTLDs – Policy Amendment Process||The ALAC has always taken the position that as a humanitarian organization, and one that has been regularly the target of those seeking to fraudulently attract donations, the Red Cross should be afforded the courtesy of having its various identifiers protected at the second level in gTLD domain names.|
|Comment: Short-Term Options to Adjust the Timeline for Specific Reviews||Of the three options presented on the public comment, the ALAC prefers the option to commence RT work upon Board action on CCWG-WS2 recommendations, to be started no later than end of June 2019. With this option, the review team will be in charge of the evaluation of implementation of prior review recommendations and other topics, with no duplication or overlap with CCWG-WS2 implementation.|
|Comment: Long-Term Options to Adjust the Timeline of Reviews||The ALAC approached the comment by separating it into two issues: (1) Organizational Reviews and (2) Specific Reviews. The ALAC recommended ICANN Org stop initiating Organizational Reviews until its is assessed how effective they have been and develop a methodology to allow them to be cost effective and effective overall. The ALAC also recommends changing the Bylaws to give the Board more flexibility with the timing of Specific Reviews going forward.|
The ALAC provided extensive community comment on (4) issues related to the Draft Proposal of the New Fellowship Program Approach, including application and selection criteria of the Fellowship Program, as well as on-site recommendations and post-meeting requirements.
|Comment: Draft Community Travel Support Guidelines||The ALAC submitted a detailed statement representing the Internet end user community within ICANN. The ALAC noted At-Large is unique within the ICANN community in that most volunteers in At-Large activities do so as true volunteers. None travel in support of their employers, few are employed by what could be considered the domain name industry or in activities supporting it, and many are not even employed in jobs supporting the Internet.|
|Comment: Release for Registration one .COM Domain Name with a Single-Character Label: O.COM||During ICANN62, the ALAC revised, ratified and resubmitted their statement. The ALAC supported the proposition, provided it offers the proceeds to nonprofit organizations that serve the public interest. The ALAC offered three suggestions to that end: (1) ICANN should permit the release of O.com and allow Verisign to conduct a third-party auction, (2) Third-party auction service providers should screen candidates for auction, and (3) Verisign should forfeit the auction’s proceeds and renewals to non-profit entity.|
|Comment: Draft Final Report of the RSSAC2 Review||The ALAC is responsible for representing the interests of Internet end users within ICANN, and there are few parts of the Internet as critical as the Root Server System. The ALAC commented specifically on recommendations 1, 2 and 5 of the RSSAC2 Review, related to 1) RSSAC membership criteria, the 2) RSSAC charter and 3) engaging more effectively with ICANN.|
|Comment: CCWG-Accountability WS2 Final Report||The ALAC noted that the assurance of full consistency between all of the recommendations - which are noted in the report to be more than 100 - would depend primarily on the interpretation of the recommendations and the implementation plan. The ALAC recommends dedicating enough time to ensure inconsistencies do not result due to misinterpretation of the recommendations.|
|Comment: Draft Final Report of the NomCom2 Review||On the whole, the ALAC believes the ICANN NomCom system has been working well considering the significant challenges it faces. The ALAC made 8 general comments to improve the function of the NomCom, noting that while confidentiality needs to be maintained, whenever possible, open, transparent processes should be adopted to represent the multistakeholder nature of ICANN.|
|Comment: ICANN Reserve Fund: Proposed Replenishment Strategy||The ALAC supports the overall strategy, with several important conditions related to operational savings, auction proceeds, per-domain registrar fees and revenue.|
|Comment: Draft Project Plan for the Proposed Name Collision Analysis Project (NCAP)||As the principle voice of end users within the ICANN community, the ALAC supported the SSAC in its efforts to address the issue of Name Collisions, while encouraging clarity on the SSAC's bidding process for work contemplated under the Draft Project Plan.|
|Comment: Draft Procedure for Community gTLD Change Requests||Community TLDs are of crucial importance to At-Large. The ALAC supported the Draft Procedure (including the proposed Community gTLD Change Request Form), subject to three provisos articulated in the Statement.|
|Comment:Plan to Restart the Root Key Signing Key (KSK) Rollover Process||The ALAC provided several recommendations to ICANN regarding the impending KSK Rollover, and called for a holistic review including a risk assessment of the alternatives, in time for further discussion at ICANN62.|
|Comment:Data Protection/Privacy Issues: ICANN-proposed Interim Model||Overall, the ALAC agreed with the Interim Compliance Model’s tiered access approach, while remaining divided on several other issues including purposes of processing WHOIS data, applying the Interim Model on a global basis, and distinction between legal and natural persons.|
|Comment: ICANN Fellowship Program Community Consultation||The ALAC suggested that changes are required in order to achieve greater effectiveness of the Program, not only to meet At-Large policy goals relating to the DNS.|
|Comment: ICANN Draft FY19 Operating Plan and Budget and Five-Year Operating Plan Update||The ALAC supports a balanced budget, while recommending increases be clearly explained and cuts refrain from targeting the most vulnerable community volunteers and activities.|
|Comment: Proposed Incremental Changes to the ICANN Meetings Strategy||The ALAC agrees with no change regarding the Community Forum, but recommends at least 5 days for outreach at Policy Forum and 6 days plus 1 additional for wrap up activity at the AGM.|
|Comment:Competition, Consumer Trust, and Consumer Choice Review Team - New Sections to Draft Report of Recommendations||The ALAC overall supports Recommendations A, B, C, D and “Recommendation 5” relating to DNS Abuse.|
|Comment: Recommendations to Improve ICANN's Office of Ombudsman (IOO)||The ALAC recommended language diversity in Staff resource configuration, and is of the opinion policing of the Ombudsman should not be a solution to fix a performance issue.|
|Comment: Recommendations on ICANN Jurisdiction||The ALAC fully supports the Subgroup proposal, articulating the need for a path forward for Jurisdiction concerns beyond the CCWG, developing another multistakeholder process to resolve these concerns.|
|Comment: Recommendations to Improve ICANN Staff Accountability||The ALAC fully endorses the CCWG Accountability recommendations, noting the suggestions to deal holistically with any contentious staff accountability issues are well developed.|
|Comment: Enhancing Accountability - Recommendations for Diversity||The ALAC supports the recommendations for enhancing diversity as a whole, while emphasizing the need for language diversity and captioning/real time transcription (RTT) services, particularly for those whose first language is not English.|
The ALAC supports having the Reserve Fund at the level of 12 months expenses, and higher if there is a practical way of achieving that without unduly impacting ICANN’s ability to provide necessary services. At whatever level the Reserve Fund target is set, the ALAC suggests ICANN must publish a plan on how and when this will be achieved.
The ALAC echoes the rationale provided by the GAC. Specifically: One of ICANN’s core values is to seek and support “broad, informed participation reflecting the functional, geographic, and cultural diversity of the Internet at all levels of policy development and decision-making to ensure that the bottom-up, multistakeholder policy development process is used to ascertain the global public interest and that those processes are accountable and transparent” (Bylaws Section 1.2.c.ii). In the view of the GAC and the ALAC it is not only among ICANN’s core values but also critical to ICANN’s legitimacy to act in the global public interest to allow non-expert stakeholders to meaningfully participate in ICANN’s processes and make their voices, their needs and interests heard, and duly take them into account in order to act and take decisions that are in fact, in the global public interest. These proposed measures will go some way to address this.