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Date Submitted to ICANN Public Comment

ALAC Statement
(Comment, Advice, Correspondence)

Executive Summary


Comment: DRAFT PTI and IANA FY21 Operating Plan and Budgets

The ALAC noted that the proposed PTI and IANA FY21 Operating Plan and Budgets are aligned with the ICANN Strategic Plan, and are also very similar to previous years' budgets. An adjustment in the PTI budget is noticeable, including adjustments in salaries, services and other administrative cross-charges from ICANN to PTI or IANA.

However, the ALAC pointed out that even though this evolution involves a big change is in process in the governance Governance of the Root Server System, these changes are not reflected in the proposed PTI and IANA FY21 Operating Plan and Budgets. The ALAC asked several exploratory questions in their response.


Comment: Next Steps to Improve the Effectiveness of ICANN’s Multistakeholder Model

The ALAC summarized its comments as follows:

I. Strengthen ICANN’s bottom-up multistakeholder decision-making process and ensure that work gets done and policies are developed in an effective and timely manner.

Issue 1: Prioritization of work. ALAC feels this must be addressed (Category A). Some suggestions include: spreading the workload, increased outreach (ATLAS III, further incentives to keep contributing volunteers, adequate knowledge and resources (specified in II) The entire community,as well as must contribute to the resolution of this problem.

Issue 2: Precision in scoping the work. This issue may fall into Category A - must be addressed - or Category B -- might be partially addressed in current processes. We foresee scoping that is tight and smart and relevant to the process. It is impossible to say who should be responsible when so much activity around it is unresolved.

Issue 3: Efficient use of resources. This is a category A issue which must be addressed. We recognize that it might be partially addressed by current processes but cannot assess the situation until these processes are completed. We are concerned that PDP 3.0 may offer efficiency at the cost of inclusiveness which we feel would be a backwards step in the evolution of ICANN’s MSM.

Issue 4: Roles and responsibilities and a holistic view of ICANN. This is a category A issue although it will require further processes to resolve. ALAC seeks a bottom-up review of roles and responsibilities as an independent process. 

II. Support and grow active, informed and effective stakeholder participation.

Strategies to expand the concept of participation are offered as well as various resources and support needed to ensure informed participation. We consider this to be a Category A issue -- the model cannot evolve if it is not addressed. This is a major concern for At Large and other volunteer-based constituencies and all will need to be involved in addressing it. Support from ICANN,org and the Board will be necessary.

Issue 5: Representativeness and inclusiveness. Mentorship programs are a key part of ensuring that the MSM system remains representative and inclusive. Relevant constituencies as well as staff need to make sure these programs are working as they are intended and that they are reaching the right demographics. Inclusiveness at the leadership level needs to be improved through a bottom up process with staff assistance.

III. Sustain and improve openness, inclusivity, accountability and transparency.

Issue 6: Culture, trust and silos. This is a category A issue that needs to be addressed in this process. All constituencies need to reach across their boundaries, respect for other viewpoints must be reinforced. This is a problem in many large organizations and there are professional services available to help build trust and cooperation. By engaging some of these services, could help constituencies build a better working environment. 

Issue 7: Complexity. This is an inherent feature of ICANN work, but where it can be alleviated, should take the lead. Make sure information such as the website is well organized and understandable and closely monitor the internet governance environment for issues that will impact ICANN directly.

Issue 8: Consensus. Creating conditions that would facilitate consensus is the goal of the issues already listed. Preserving the voice of end users in the decision-making processes is crucial to ICANN’s MSM model -- a Category A issue in which all parties play a role but the role of the Board will be particularly important. 


Comment: Proposed Definition of Name Collisions and Scope of Inquiry for the Name Collisions Analysis Project

The ALAC considers the issue of Name Collision in the DNS an area of importance for the minimization of unintended consequences for Internet end users. The ALAC appreciates the need to have a Name Collision definition for purposes of scoping the inquiry for the Name Collision Analysis Project (NCAP), in order for the NCAP Study One to be manageable and on point, and therefore supports the Proposed Definition of Name Collision and Scope of Inquiry for the Name Collision Analysis Project of 1 July 2019. Of particular importance to us are:

(1) The recognition and inclusion of Type B situations (ie. B. In scope but not intended to be the subject of data studies) which provides built-in peripheral consideration of such situations with decision for examination through data analysis at a later stage if a compelling case were to arise within Study One; and

(2) The possibility of amending the Definition of Name Collision and Scope of Inquiry for the Name Collision Analysis Project should further pertinent information come to light at a later stage either through the ongoing work of the NCAP DG, NCAP Working Party and/or input obtained from the party/ies eventually contracted to undertake NCAP Study One.  


Comment: Evolving the Governance of the Root Server System

The ALAC strongly supports the overall proposal and appreciates the opportunity to comment. The RSS, according to RRSAC37, needs to evolve so it remains a reliable, resilient, and sustainable service in the face of increasing traffic and cyberattacks. However, the ALAC finds it difficult to accept that ICANN is not considered a primary stakeholder with regard to the RSS, given that the Domain Name System and its reliable and trusted operation is a prime reason for ICANN’s existence. The ALAC also encourages that Internet users, the ultimate user and beneficiary of the DNS, should be listed as having a stake in the existence and evolution of the RSS.

The financial model is also of some concern to the ALAC. No figures are provided to allow even order-of-magnitude estimates. It is surely time that we begin to understand exactly what level of funding will be required and hypothesize on where such funding will come from.


Comment: Draft Financial Assumptions & Projections and Operating Initiatives for the development of Fiscal Years 2021-2025 Operating & Financial Plan

The ALAC considered the Draft Financial Assumptions, Projections and Operating Initiatives, and offered comments on the following topics among others: 

  • The ALAC is not optimistic that Financial Assumptions A (Roll-out of New gTLDs) and B (New Business Models – Geographic gTLDs and Brand gTLDs) will be highly successful vehicles to new revenue. Although the first round of new gTLDs did bring in considerable revenue, the ALAC notes that these earlier rounds represented the “low hanging fruit” in the new gTLD market.
  • The ALAC agrees that ICANN continue to put money towards the an urgent need to resolve current challenges around Universal Acceptance, as well as the primary strategic goal of security, stability and trust.
  • The ALAC agrees that work which needs to be done on evolving the multistakeholder system is substantial and complex and that it must be ongoing with adequate resources directed towards its completion. The objectives related to diverse and inclusive participation in policy making in an efficient and effective way are essential to improving the system, underlining that face-to-face meetings are essential to the functioning of the multistakeholder model.
  • The ALAC/At-Large community propose some clarity via a listing of priorities and statements on the impact of each project on ICANN org and on each of the unique ACs and SOs. The community believes that while policy development and implementation activities are integral to the planning process, so are other activities, such as those that enable communication, collaboration, and outreach, between RALOS, At-Large members and other constituencies.


Comment: Proposed IANA SLAs for Publishing LGRs/IDN Tables

The ALAC supports the recommendations of the CSC and PTI for the proposed IANA SLAs for publishing the LGRs/IDN Tables.


Comment: Fundamental Bylaws Amendment Proposal – IANA Naming Function Review 

The ALAC supported the current version of the ICANN Bylaws Section 18.7(a) and 18.7(b), but understands that it has now proven to be difficult to implement. The ALAC agrees that the proposed change preserves the intent of the original Fundamental Bylaw and supports the change. Subject to any new information being brought to the ALAC’s attention, the current intention is that the ALAC will support this Fundamental Bylaw change when it is presented to the Empowered Community.


Comment: Evolving ICANN's Multistakeholder Model

The ALAC contribution to the evolving multistakeholder model condensed the 21 issues developed through community consultations into 4 general categories: (1) structural, (2) process, (3) participation and (4) intergroup relations. Regarding structure and process, the ALAC recommends more specific scoping, the use of external influences and project management tools, easily retrievable records of discussions and decisions and joint community/staff priority setting. Regarding participation, the ALAC noted the multistakeholder system depends on wide participation in the process and wide participation from all regions remains a challenge, including language barriers and volunteer burnout. Finally regarding intergroup relations, the ALAC noted there will always be disagreements,  but a culture of positive relations between and among groups must be actively encouraged.


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),
(ii) inclusion of Minimum requirements for Rights Protection Mechanisms (per Specification 7), 
(iii) adoption of the Registry Code of Conduct (per Specification 9), and
(iv) amendment of the relevant section in Specification 5 to govern the allocation of two-character labels at the second level to avoid confusion with corresponding country codes.

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:

  • Request that the issue of Thick WHOIS be discussed during the EPDP Phase 2 in light of the new legal opinion;
  • Request that the issue of geographic differentiation be re-opened during the EPDP Phase 2 in light of the new legal opinion and the lack of considering the competing needs of privacy vs the benefits of non-redaction on cyber-security activities and that the ensuing discussion factor in the needs of those using the data for cyber-security and other legitimate purposes;
  • Request that the issue of legal/natural differentiation be discussed during the EPDP Phase 2 explicitly considering the competing needs of those using the data for cybersecurity and other legitimate purposes;
  • Initiate independent studies related to the implementation of geographic and legal/natural differentiation as well as the impact of the Temporary Specification implementation on cyber-security, or request that the EPDP Phase 2 commission such studies. If the latter, the Board should ensure adequate funding for such work.


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.


Comment: Updated Operating Standards for Specific Reviews

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 ProcessThe 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 UpdateOf 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.


Comment: Work Track 5 on Geographic Names at the Top Level - Supplemental Initial Report of the New gTLD Subsequent Procedures Policy Development Process

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 ProviderThe 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 TeamThe 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 DomainsThe 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 & RecommendationsAs 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 GroupThe 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 RecommendationsThe 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 ModelThe 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 BudgetsAfter 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.


Advice: Follow-Up to the Joint Statement by ALAC and GAC: Enabling Inclusive, Informed and Meaningful Participation at ICANN  

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) ProfileThe 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 ReviewsThe 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 DomainsThe 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 3.0The 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.


Comment: IPC/BC Accreditation & Access Model for Non-Public Data v1.7 

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.


Comment: Draft Proposal of the New Fellowship Program Approach

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.COMDuring 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 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 ReviewThe 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 ReportThe 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 ReviewOn 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 StrategyThe 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 RequestsCommunity 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 ProcessThe 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 ModelOverall, 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 ConsultationThe 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 UpdateThe 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 StrategyThe 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 RecommendationsThe 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 JurisdictionThe 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 DiversityThe 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.

Comment: ICANN Reserve Fund – Public Comment on Rationale and Target Level 

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.

Advice: Enabling Inclusive, Informed and Meaningful Participation at ICANN - A Joint Statement by ALAC and GAC

Note: submitted to ICANN Board as ALAC Advice; ratified during ICANN60.

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.