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04 March 2020

DRAFTING

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FINAL VERSION SUBMITTED (IF RATIFIED)

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FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC

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DRAFT SUBMITTED FOR DISCUSSION

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Draft submitted by Alan Greenberg and Jonathan Zuck, 25 February 2020, 16:20 UTC


The ALAC appreciates the opportunity to comment on the Second Security, Stability, and Resiliency (SSR2) Review Team Draft Report.

Ensuring the security, stability and resiliency of the DNS is arguably ICANN's single most important role.

SSR1 issued 28 recommendations. The ICANN Org reports indicated the Board judged all to be relevant and implementable and that all were fully implemented. The SSR2 analysis was that of the 28 recommendations, 2 were not implemented at all, 26 were partially implemented and none fully implemented. Of these 27 of the 28 were found to still be relevant. That is an astounding analysis 8 years after the acceptance of the SSR1 recommendations.

The ALAC has a particular interest in the recommendations related to domain name abuse, and notes that several of the recommendations overlap with and complement those issues by the RDS-WHOIS2-RT [and the CCT RT?].

The ALAC also notes that in the opinion of the SSR2 RT, many of the recommendations are deemed to be of high priority. Given the current interest in ICANN of prioritizing activities with the implicit effect of not addressing those lower on the list, this could lead to not addressing issues critical to the SSR of the DNS. DNS Security, stability and resiliency is not something that we can afford to ignore. The lead item in ICANN's Strategic Plan is "Strengthen the security of the Domain Name System and the DNS Root Server System.". This must be taken into account when allocating resources and we trust that this will be taken into account when the Board works with the RT Implementation Shepherds on deciding how to prioritize the recommendation implementation.

Summary:

We are living in a world where many parties seem to have a interest in destabilizing critical infrastructure and the Internet in particular. The fact that our systems have been sufficiently robust in the past is not an indication that this is sustainable moving forward. ICANN needs to take seriously the need to professionally and rigorously ensure the SSR of its DNS operations. In particular, known vulnerabilities need to be corrected with the utmost haste.

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