Executive Summaries: ALAC Statements (Comments, Correspondence, and Advice)

The ALAC and At-Large continue to support the recommendations made by ATRT3 regarding Reviews, Holistic Review(s), and the implementation of Continuous Improvement Programs. The ALAC is in favor of having the 'pilot' holistic review started as quickly as possible and proposes that ICANN org consider the benefits of running various preparatory phases as outlined in the Terms of Reference. 

The ALAC fully supports the GAC's advice, which states that "Prior to the next round of New gTLDs, to ensure that the forthcoming Applicant Guidebook clearly states that Closed Generic gTLD applications will not be considered." Additionally, the ALAC believes that the differences among the various parties on what would satisfy a public interest or the global public interest may be irreconcilable, and that the benefit of Closed Generic gTLDs are not worth expending more community time and ICANN resources.

The ALAC and At-Large community are supportive of the important role that the ccTLDs Managers serve within the ccNSO and the broader ICANN community. However, the ALAC believes that the proposed amendments to the ICANN Bylaws should be expanded to provide additional standing for “significant stakeholders” and “relevant government” under the proposed review mechanism.

The ALAC and the At-large community express their support of the proposed recommendations. The ALAC would like to draw attention to the ICANN Board’s resolution regarding managing the IDN variant TLDs, requesting a consistent solution is developed for both IDN variant ccTLDs and IDN variant gTLDs. The ALAC considers the Board’s resolution not only important for ensuring consistent implementation and rationale but also for maintaining consistent user experiences.

The ALAC is pleased to submit its proposal on resolving two concerns regarding Subsequent Procedures Recommendations 17.2 on Applicant Support. The ALAC reinforces its position that the Applicant Support Program is an essential component of the New gTLD Program. The ALAC believes the approach to providing applicant support services must be holistic in order to be able to support deserving applicants throughout the application and evaluation processes up to approval, and preferably including support for the post-approval stage. The ALAC believes that there should be no payment made directly to third party services providers. Additionally, the ALAC believes that the optimal way to implement a holistic ASP is by way of an ASP Incubator. 

The ALAC fully supports the efforts of the Transfer Policy Working Group to facilitate the prompt and secure transfer of domain names to a registrar/reseller of their choice.  The ALAC disagrees with the preliminary draft recommendation as it presupposes an outcome that is detrimental to the interests of individual internet users. The ALAC is of of the view that Registrants should be given the opportunity to initiate the Registrar Transfer Dispute Resolution Policy and finds it unreasonable that the only option for Registrants is to take inter-registrar transfer disputes to court. 

The ALAC is of the view that the Closed Generics Draft Framework lacks sufficient intent and clarity to be operationally useful, though a follow on PDP may add sufficient clarity. The ALAC is of the view that the framework is both too complex to be useful to public interest organizations and too vague to disallow anticompetitive outcomes that drove opposition to closed generics in the previous round. 

The ALAC and At-Large community strongly supports the RA an RAA amendments to modify DNS abuse contract obligations. The ALAC and At-Large community appreciate the accompanied Draft ICANN Advisory, which provided guidance and expectations for action by registrars and registries to ensure compliance with the new contractual terms. The ALAC and At-Large community commend the Registrar Stakeholder Group, the Registry Stakeholder Group and ICANN Org and hope that there continues to be a collective effort to effectively combat DNS Abuse both as currently defined, and as it may evolve over time.

The ALAC brings to the attention of the GNSO Council the diacritic issue with .Québec and the Latin script Root Zone Label Generation Rules' (RZ-LGR) preclusion of some perceived variants. 

In general, the ALAC supports the preliminary recommendations and implementation guidance proposed by the EPDP in its Phase 1 Initial Report, and highlights specific comments of support and concerns. 

These specific comments were attached as a PDF to supplement the ALAC’s responses submitted via this guided form on the following topics: Root Zone - Label Generation Rule (RZ-LGR), Same-Entity Principle, Application Fee Regime for Variants, and the Glossary.

At a high level, overall, the At-Large Community and the At-Large Advisory Committee (ALAC) are supportive of the

1. Change proposed by the NomCom2 Review to define Unaffiliated Board Members (i.e., Directors). However, the At-Large Community is split in how this term “Unaffiliated” is defined.
2. Granting of voting rights to the current non-voting delegates so that all delegates are treated equally. 
3. Creation of a NomCom Standing Committee to provide continuity across annual NomCom cycles and to build the institutional memory of the NomCom. 
4. Change to Article 12 in the ICANN Bylaws.

The ALAC and At-Large community are supportive of the majority of updates to the .NET contract including provisions concerning RDAP; DNS Abuse mitigation commitments; and use, by ICANN, of the Bulk Registration Data Access (BRDA) for research.

We have recommendations related to the boundaries of consensus policy with respect to .NET, the need for a comparison between .NET and the Base Registry Agreements (RAs), and the need to revisit Registry Operator participation in economic studies (including .NET).

The ALAC thanks ICANN org for the important reduction of pages of this Operational Plan & Budget, without losing the explanations of the budget, operational plans, and initiatives. As it has been in the last years, it is presented in a very readable format, with bookmarks embedded in the document. We also appreciate the inclusion of the budget ‘highlights’ that provide a good summary of the two documents for those without the time to read both documents.

The At-Large community provided comments on the following areas:

FINANCIAL PLANS AND BUDGETS

• Draft FY 24-28 Financial Plan
• Draft FY 24 Budget

OPERATING INITIATIVES

• Support the evolution and strengthening of the root server system and root zone management
• Facilitate the Domain Name System (DNS) Ecosystem improvements
• Evolve and Strengthen the Multistakeholder Model to Facilitate Diverse and Inclusive Participation in Policymaking
• Evolve and Strengthen the ICANN Community’s Decision-making Processes to Ensure Efficient and Effective Policy Making
• Promote and Evolve the DNS Through Open and Transparent Processes That Enable Competition and Open Entry in Internet-Related Markets While Ensuring the Stability, Security, and Resiliency of the DNS
• Evolve and improve internal and external ethics policies
• Global Stakeholder Engagement
• Geopolitical Monitoring, Engagement and Mitigation

FUNCTIONAL ACTIVITIES

• Policy Development and Support
• Community Engagement and Services

The ALAC commends the Country Code Names Supporting Organization (ccNSO) Policy Development Process Review Mechanism Working Group on completing the initial report and would like to offer its support to the included recommendations. 

The ALAC would like to stress the importance of ensuring that any review mechanism process does not result in end user confusion or inconvenience. 

Country Code Top-Level Domain (ccTLD) end users must be prioritized when performing any review mechanism. Commitment to due process and policies such as these will help ensure the consideration of end users.

The At-Large Advisory Committee (ALAC) thanks ICANN org for its enormous effort preparing the ODA. While analysis of the ODA is ongoing, we thought it worthwhile to provide some high level commentary, in the run up to the ICANN Board discussion of the ODA. Outlined in this letter are a number of high-level comments and concerns related to ALAC priority topics covered by the ODA as well as specific concerns regarding the differences between Option 1 and Option 2.

Ahead of ICANN76, the ALAC is conducting an analysis of the ODA in comparison to its 2021 Advice to the ICANN Board on Subsequent Procedures and its related response to the ICANN Board’s Clarifying Questions. The objective of this analysis was to review several key priority topics and identify

• Areas where further discussion is needed, and/or topics we thought might be clarified by the Operational Design Phase (ODP) process but were not.
• Problematic assumptions made in developing the ODA.
• New issues raised in the ODA for the ICANN Board to consider.

The ALAC and At-Large community support almost all of the recommendations in the Initial Report, with a few minor exceptions:

• The role of chair should be filled by a CSC liaison when no CSC member is available to chair the role. 
• The reports on the Service Level Agreements (SLAs) performance should continue to be circulated on a monthly basis.

The At-Large Advisory Committee (ALAC) has comments and concerns in regards to the following sections of this Public Comment proceeding:

1. Section 4: Effective Date
2. Section 10: Disclosure requests
3. Background Section of the Registration Data Consensus Policy
4. Thick Whois Transition Policy

This policy sets the necessary foundation for the processing of generic top-level domain (gTLD) registration data. Namely, the purposes for the processing of the gTLD registration data and data elements required to be collected, published and redacted, it is important to accurately implement this policy in due time.

We would like to note that according to recommendation number 18, response time to disclosure requests were meant to be finalized through the requirements set during the implementation stage. As such we do not agree with section number 10.6 as it sets responses to urgent lawful disclosure requests to up to two business days. This would mean if a request comes on a weekend, the response to an urgent lawful disclosure request could be provided after four days. We need to remember that urgent requests are requests related to circumstances that pose an imminent threat to life, serious bodily injury, critical infrastructure, or child exploitation. Therefore, the response time set in section 10 in relation to urgent requests will  not satisfy the purpose of the request.

The ALAC also notes that in accordance with recommendation number 18, the ALAC does not expect that the implementation of Section 10 (Reasonable requests) will prevent or hinder the undergoing work in relation to a standardized system for access/disclosure (SSAD).

The ALAC and At-Large are in support of the budgets as proposed, with a few exceptions. 

The ALAC has concerns regarding the Public Technical Identifiers (PTI) headcount, travel expenses, and budget. They are also concerned that critical functions of the PTI are being passed to professional services. Further explanation is included in our statement below.

The At-Large Advisory Committee (ALAC) and the At-Large community are clear on the purpose and potential of recommendation 3.5 from the Third Accountability and Transparency Review Team (ATRT3). As with other recommendations made by ATRT3, this recommendation is fully supported, as outlined in the January 2020 ALAC statement. 

The ALAC and At-Large community strongly endorse the principle of a regularized Holistic Review as part of the overall ICANN org Review cycle. Therefore, we support the proposed draft Terms of Reference (ToR) while the Holistic Review is in this pilot phase. 

The ALAC and At-Large welcome this opportunity to respond to the specific questions posed in the call for Public Comment. Please note that the ALAC and At-Large:

1. Support the Pilot Holistic Review Terms of Reference as drafted.
2. Agree that the Holistic Review Program outlined in Section II of the Draft Terms of Reference provides a clear approach to accomplishing ATRT3’s objectives while addressing the information gaps identified by the ICANN Board.
3. Agree that the steps and the deliverables associated with each ATRT3 recommendation 3.5 objectives, as described in Section II of the Terms of Reference, are clearly defined and outline the scope of work for the Pilot Holistic Review.
4. Appreciate the clarity that the steps and the deliverables associated with each ATRT3 Recommendation 3.5 objective, as described in Section II of the Terms of Reference, explain how Supporting Organizations, Advisory Committees, Nominating Committee, as well as their constituent parts, participate in the process of establishing a Holistic Review Program.

In summary, the ALAC/At-Large show strong support for the process and see this Public Comment proceeding as an opportunity for the ALAC/At-Large to contribute comments that help ensure a rapid start to the long-awaited Holistic Review. 

Related: ALAC statement on ATRT3 (January 2020).

The ALAC believes that the Roadmap will highlight the issue of UA compliance within the registry and registrar communities, and will assist the community to achieve compliance. However, there are a few areas where the ALAC believes the Roadmap could be improved: 

The report has chosen not to consider the issue of Internationalized Domain Name (IDN) variants.

There is no mention of the role of resellers.

The report does not take into account the continuing changes to access mechanisms for registration data.

The At-Large community is focused on the Registrant and End-User perspective, and supports processes and policies that make an Inter-Registrar Transfer and a Change of Registrant simple, safe and secure.

At-Large supports a transfer policy that makes an Inter-Registrar transfer of a registered domain name as secure and fast as possible. At-Large believes that the charter questions and the work done in the TPR WG, as written in the Initial Report for Phase 1a, mostly support this position.

In light of the ICANN Board's ongoing focus on NIS2 issues and the EPEP Phases 2A recommendation, the ALAC is prepared to withdraw this item of advice and re‐issue it should the situation warrant it in the future.

Related: EPDP Phase 2A Policy Recommendations for ICANN Board Consideration (13 Jan 2022)

The additions ICANN org made to the FAQs do not modify the initial comments contained in the ALAC Advice on the ICANN74 Travel Acknowledgement (May 2022).

The ALAC Advice was concerned with the waiver itself -- which is a stand alone legal document. Objections to the waiver centered around the fact that it went well beyond health and safety conditions related to Covid-19 and participants were asked to waive any and all rights to seek redress from ICANN, regardless of the situation under consideration. The FAQs address health and safety measures put in place to manage potential Covid-19 situations. However, they do not change the waiver itself. If the waiver had not made absolute statements and had referenced the other documents, the situation might have been different.

Related: ALAC Advice to the Board on the ICANN74 Travel Acknowledgement (2 May 2022)

Advice: ALAC Advice to the Board on the ICANN74 Travel Acknowledgement

ALAC submitted a request for the ICANN74 Travel Acknowledgement to be rewritten. They do not believe that the waiver takes into consideration important overarching principles, such as the trust relationship between ICANN and its important volunteer base and the bottom-up multi-stakeholder model, in which ICANN takes such great pride within the Internet community.

Related: ALAC Response to ICANN Org Clarifying Questions on the ALAC Advice on the Travel Acknowledgement (31 May 2022)

ALAC identified specific problems that a policy development process would be expected to address, such as domain names registered for malicious activities and the effects of GDPR. As an outcome, ALAC identified a reduction in the number of domain names registered for malicious intent. 

In terms of next steps, ALAC recommends the GNSO Council's appointment of a small team consisting of experts of the ICANN Community to develop a catalog of activities to be targeted. 

The ALAC provided comments on the Draft FY23-27 Operating & Financial Plan and Draft FY23 Operating Plan and Budget regarding budget allocation, funding, and expenses.  

The ALAC also commented on policy development and advice improvements planned such as work related to the evolution of the ICANN Multistakeholder Model. ALAC stated it did not want to see the Holistic Review delayed. 

The Continuous Improvement program of all SOACs will be an ongoing effort, in parallel with the new Holistic Review. Budget allocation must be provided in FY23 and beyond, in order to ensure its completion before a second Holistic Review no more than 2.5 years after the initial implementation of recommendations from ATRT4.

ALAC has no concerns pertaining to the proposed ccNSO retirement process of ccTLDs. ALAC supports positions to ensure a transparent and smooth process that considers all stakeholders in its implementation.

ALAC supports the approach, definition and process descriptions outlined in this proceeding and wishes the ccNSO to keep the two following items in mind:

Assessing the impact of the retirement of a ccTLD on national interests and registrants.

Having a clear review process for the two issues that could trigger a review mechanism.

Comment: EPDP Phase 2A Policy Recommendations for ICANN Board Consideration

Alan Greenberg submitted a comment as ALAC representative to the PDP.

Related: EPDP 2 (SSAD) ALAC Response to the Board's Understanding of the ALAC's Response to the Board's Clarifying Questions on the ALAC Advice (3 June 2022)

ALAC responded to eleven topics on which the ICANN Board requested clarification. Topics include

Timing and Operational Design Phase,

New gTLD Program Objectives and Metrics,

CCTRT Recommendations related to Subsequent Procedures,

DNS Abuse Mitigation,

Enforceability of Registry Voluntary Commitments (RVCs),

Universal Acceptance,

Name Collision,

Closed Generics,

Applicant Support,

Auctions and Private Resolution of Contention Sets,

Community Priority Evaluation (CPE),

Geographic Names at the Top Level

Related: ALAC Advice to the ICANN Board on Subsequent Procedures (16 April 2021)

Comment: Proposed Revisions to the ICANN Documentary Information Disclosure Policy

ALAC stresses the importance of information disclosure in establishing the trust and support of Internet end users in ICANN.

The ALAC recommends ICANN to:

Allow Ombuds to oversee the mechanism for requestor review of ICANN DIDP responses.

Document within the DIDP Policy any available recourse if a DIDP is not fully satisfied.

ICANN must evaluate whether to release material, but the DIDP exists to ensure that ICANN is transparent.

It is the considered position of the ALAC that, while great strides have been made by the Latin Generation Panel, more must be done to enable more users, with sufficient security, to use the DNS.

The ALAC Recommends the Latin Generation Panel (LGP) to:

Establish a lower bar for possible confusion, as they are the experts - not typical end users.

Revise their conclusion that the underlining of domain names (as happens routinely) does not obscure diacritics below the line.

Revisit the instructions attributed to the IDN Project, and consider treating capital letters as a special case.

Include all of the languages which use the Latin script - at a minimum, languages which have more native speakers than the smallest of the “official languages” which are already included, should be added.

The ALAC noted that the FY23 Operating Plans and IANA budget look robust, indicating an improvement of PTI and IANA functions. The ALAC values the opportunity to be involved in the annual PTI planning process, and provided comments referring to the FY23 PTI budget.

The ALAC takes the position that domain names which are identical to the respective acronyms of intergovernmental organizations (“IGOs”) and which are registered and used by third parties (non-IGO registrants), run a conceivable risk of creating confusion to Internet end-users, or worse where the use facilitates fraudulent activity. End-users need to be able to trust that any information delivered using such domain names emanates from the respective IGO. Thus, the ALAC welcomes the results already achieved on facilitating an IGO’s access to the ICANN-created twin dispute resolution processes of UDRP (Uniform Domain Name Dispute Resolution Policy) and URS (Uniform Rapid Suspension) in a way which preserves an IGO’s privileges and immunities.

Advice: ALAC Advice to ICANN Board on EPDP Phase 2

Comment: Initial Report of the Expedited Policy Development Process (EPDP) on the Temporary Specification for gTLD Registration Data Team – PHASE 2A

In its ALAC statement in response to the ICANN Public Comment proceeding, the ALAC noted 1) it does not support Preliminary Recommendation #1 (Phase 1 Rec. 17) regarding differentiation between legal and natural persons; 2) The GNSO Council should monitor developments in relation to the adoption and implementation of relevant legislative changes; 3) the ALAC supports a standardized data element to be available for contracted parties to use, with a field to specify whether the registrant is a legal or natural entity; 4) that if there is a standardized data element, it must be populated for registrations where a differentiation is made. The ALAC also noted that it believes that arguments that other issues (such as the RDDS Legal/Natural element) is out of scope for the EPDP-TempSpec are incorrect.

APRALO fully endorses the ratified ALAC Advice on Subsequent Procedures of 16 April 2021, and raised the following positions either in support of and/or in supplement to the said ALAC Advice: 1) Need to facilitate increased adoption of Universal Acceptance (UA) & Internationalized Domain Names (IDNs); 2) Need to facilitate increased and equitable access by “Global South”, community / niche TLD applicants through the Applicant Support Program (ASP) & Community Priority Evaluation (CPE) and a ban on private auctions; 3) Need for ALAC to have automatic standing to file Community Objections (where ALAC deems necessary).

Related: Response to Board Clarifying Questions: ALAC Advice on Subsequent Procedures (12 Jan 2022)

The ALAC focused its response on recommendations that are consistent with ALAC principles and goals, including improving accountability and transparency; expanding uses of languages other than English; improving data gathering and supporting the use of metrics; improving the comprehensibility and intelligibility of ICANN policies and requirements to the benefit of end-users (among others); and improving access to processes.

In the view of the ALAC, the SSR2 Final Report consists of a series of well-considered recommendations that would improve ICANN’s fidelity to the core principles of security, stability and resiliency that lie at the heart of ICANN’s mission. SSR2 builds on the work of the first SSR-RT (SSR1) and the ALAC is pleased to observe that the SSR2 has ratified most of the work of the SSR1, while noting with caution that implementation of the report is the most critical element of all, and one that is outside the remit of SSR2. The ALAC looks to ICANN org to make this Final Report (and the SSR1 Report) a reality with regard to each recommendation.

The ALAC encouraged the ICANN Board to fulfil their initial report recommendations in their response to the IANA Naming Function Review (IFR) Initial Report, and as the Contract Amendment is recommendation #4 of the report, the ALAC supports it. ALAC support for this proposed contract amendment is premised on their acceptance of the IFRT's rationale that it seeks to remove a now operational impracticality arising from a legacy statement from the NTIA contract (i.e., to eliminate redundancy).

The European Commission’s Proposal for a revised Directive on Security of Network and Information Systems (NIS2) is of great interest to the ALAC and the ALAC strongly supports this initiative. However, the ALAC noted that as the proposal is currently written, there are a number of gaps that will not allow it to fulfill its intended function, with relation to Article 2: Scope, Article 4: Definitions, Article 23: Databases of Domain Names and Registration Data. NIS 2, with appropriate enhancements as described in this comment, has the potential to greatly improve Internet security and the ALAC looks forward to its being adopted by the European Parliament and the Council and acted on by the Member States.

The ALAC encouraged the ICANN Board to fulfill the IFR recommendations as indicated in the report. The ALAC also congratulated the IANA Naming Function Review Team for the methodology used in the review.

Comment: DRAFT PTI and IANA FY22 Operating Plan and Budgets

The ALAC made three recommendations with regards to Early Warning Root Zone Scaling: 1) Early warning signs from the anti-abuse communities should be taken seriously; 2) Proper consultation/feedback channel or mechanism should be put in place between ICANN and the various stakeholders should there be any future RSS scaling concerns; 3) In the event that any ICANN process is severely impacted as a result of the proposed scaling, there should be a mechanism in place to pause the process.

The ALAC registered concerns about the requested amendments to the .JOBS Registry Agreement with Employ Media which would remove the nonprofit Society for Human Resource Management (SHRM) as sponsor and make Employ Media the sponsor of the .JOBS TLD in the absence of any clear rationale. The ALAC pointed out that the end user community places a very high value on the role of nonprofits as stewards of TLDs, as was evident in the recent controversy over a proposed sale of PIR. Finally, the ALAC noted it believes that it would be in the best interests of end users to maintain more robust oversight provision on behalf of the .JOBS community, and ultimately the end user community.

Comment: Reference Label Generation Rulesets (LGRs) for the Second Level

The At-Large Consolidated Policy Working Group (CPWG) held several single-issue teleconferences about the New gTLD Subsequent Procedures (SubPro) PDP earlier in 2020 in preparation for the Public Comment proceeding. A small team, led by ALAC Member Justine Chew, organized these sessions and gave weekly presentations to the CPWG on the topic. In September 2020, the ALAC submitted a statement on the GNSO New gTLD Subsequent Procedures Draft Final Report, the culmination of months of volunteer work in developing At-Large scorecards on SubPro topics, creating a survey on geographic names, and analyzing feedback from the community of Internet end users.

The At-Large community is pleased to follow up on its prior ALAC statements regarding ICANN’s Multistakeholder Model (see: 13 June 2019, 14 October 2019, February 2020) with this ALAC statement on Enhancing the Effectiveness of ICANN’s Multistakeholder Model - Next Steps. The ALAC made recommendations on priority issues, moving out of silos, restoring recruitment and demographics, reviewing previous responses, identifying gaps, pandemic related issues and evaluation of success with respect to the latest Public Comment on the topic.

The ALAC strongly supports the limited and focused number of recommendations proposed by the ATRT3 report, reflecting the pending implementation of proposals from previous review teams. In moving forward, the ALAC advises the ICANN Board to: (1) Swiftly implement ATRT3 recommendation to evolve both specific and organizational reviews as per Section 8 of the final report; (2) Fully endorse the recommendation to enhance current methods of Prioritization and Rationalization of Activities, Policies, and Recommendations (as per Section 10 of the report); (3) Share the ATRT3 Review Team’s approach to the review process and methodology behind it, aiming to ensure that all elements contributing to achieving strategic objectives and their subcomponents are Specific, Measurable, Achievable, Relevant and Time-based (SMART) and that all reporting on these refers to well specified metrics, to be reviewed on a regular or timely basis (as per Section 9 of the report).

A vast amount of work has been done, but the ALAC believes that if and when the SSAD is deployed, the probability of its meeting the goals needed by the communities whose efforts we support will be low. Therefore, in order for the ALAC to support the EPDP Final Report, the ALAC noted the following GNSO Council outcomes would be required: 

GNSO Council would agree that any Evolution Standing Committee recommendation on additional SSAD decision use-cases (that are in full accordance with the EPDP Policy Recommendation 9.3) will be treated as Implementation and not require further policy deliberations.

Legal vs Natural, Accuracy, WHOIS Accuracy Reporting System and Anonymized contact email will be fully addressed with full participation in all aspects of discussions by the ICANN Advisory Committees that wish to participate. If these issues are deemed to be policy, they must be addressed by a group empowered to make policy recommendations, led by a qualified, non-conflicted chair. The GAC, ALAC and SSAC must be involved in setting the mandate or charter of such groups. The target for completion of all work should be no later than April 2021.

The GNSO Council would agree that ratifying the Evolution Standing Committee recommendations will only require a GNSO Majority as currently called for in the GNSO Policy Manual.

The GNSO Council would acknowledge that deliberations during implementation setting of prices for the SSAD must involve the future potential users of the SSAD and not only look at cost recovery but the actual ability and willingness of SSAD users to pay the prices being set.

The LACRALO statement was in response to the ICANN Latin America and Caribbean (LAC) Regional Strategic Plan for FY2021-2025. As all LACRALO countries fall under the LAC Regional Plan, a diverse drafting team from the region provided feedback on strategy topics such as security, ICANN governance, unique identifiers system, geopolitics, and financials.

Note: Ratified by the LACRALO Leadership Team and the ALAC.

As a whole, the ALAC supports the ccNSO PDP3.  From an end user perspective, the ALAC suggested two points to be considered: 1) As a user of the Internet, the removal of a TLD will mean less likelihood for confusion as usually a ccTLD would be removed to make way for a new one. This enhances Trust in the domain name identifiers; 2) As a domain name registrant, the retirement of the ccTLD could pose a problem when correspondents are accustomed to use the "old" address using the obsolete ccTLD. Some companies have built a brand around the "old" ccTLD.

The ALAC strongly supports the SSAC in proceeding with Studies 2 and 3, and it also strongly urges the ICANN Board and ICANN Org/OCTO to take the necessary action to facilitate the conduct and funding of the NCAP Studies 2 and 3 in a manner agreeable by the SSAC.

The ALAC supports the five strategic objectives of the Draft PTI Strategic Plan, and strategies to achieve those objectives. The ALAC particularly supported the following elements: Awareness of PTI's mandate and remit, alignment of ICANN and PTI’s Strategic and Financial Plans, and input into the development of ICANN policies.

The AFRALO statement was in response to the ICANN Africa Regional Plan for Fiscal Years 2021-2025. As all AFRALO countries fall under the Africa Regional Plan, a drafting team from the region provided feedback on strategy topics such as security, ICANN governance, unique identifiers system, geopolitics, and financials.

Note: Ratified by the AFRALO Leadership Team and the ALAC.

The ALAC commented on the Expedited Policy Development Process (EPDP) on the Temporary Specification for gTLD Registration Data Team – Phase 2, via a comprehensive Public Comment Google form. The ALAC provided feedback on related issues such as display of information, legal versus natural persons, privacy, et al. For all recommendations not listed in the ALAC statement, the ALAC noted that they they “Support as written”.

The ALAC noted that At-Large is unique within the ICANN community in that virtually all volunteers in At-Large activities, including those involving travel, do so as true volunteers. Without ICANN travel support, the number of active At-Large participants at ICANN meetings would be few in number. The ALAC specifically commented on wire transfer and foreign exchange fees/losses, visa reimbursement, travel insurance, ICANN arranged travel, room guarantees, forced overnight delays, early check-in and late check-out, as they pertain to the successful participation of the community during ICANN meetings.

The AFRALO and APRALO joint statement was the first joint RALO statement within the At-Large Community, in response to the ICANN MEAC Strategy 2021-2025. The countries that fall under the MEAC Strategy within AFRALO and APRALO provided feedback on strategy topics as security, ICANN's governance, unique identifier systems, and geopolitics.

Note: Ratified by the AFRALO & APRALO Leadership Teams and the ALAC.

The ALAC suggested several significant recommendations to the NextGen@ICANN Program, to the benefit of the community by opening the program and ensuring a welcoming environment to all NextGenners, including first time participants. The ALAC's recommendations would ensure that participants are selected with a stronger focus on their work and can then attend more than one meeting to engage with the community and find their “policy home”. As a part of its recommendations, the ALAC stated that At-Large would welcome a more active participation of NextGenners in its community.

For all recommendations not listed in the ALAC statement, the ALAC noted that they they “Support as written”. The ALAC “supported wording with change” for several other recommendations - 1, 6, 7, 9, 15, 19 - and made a general comment that differentiation between natural and legal persons would offload the system from unnecessary queries that are permissible under GDPR.

The ALAC noted that ensuring the security, stability and resiliency of the DNS is arguably ICANN's single most important role. The ALAC has a particular interest in the recommendations related to DNS Abuse, and notes that several of the recommendations overlap with and complement those issued by the RDS WHOIS2-RT and the CCT RT. DNS Security, stability and resiliency is not something that we can afford to ignore.

The ALAC has a particular focus on and interest in DNS Abuse. To address this may require contractual changes to facilitate Contractual Compliance action. Such changes require either negotiations with the contracted parties or a PDP, and the ALAC recommends against a PDP and instead encourages ICANN to come to an agreement with contracted parties. Known vulnerabilities need to be corrected with the utmost haste.

Note: Not an ICANN Public Comment. The Public Interest Registry (PIR) held a Public Comment proceeding on the issue of the ISOC/PIR. (8) responses were submitted on behalf the ALAC to the PIR Public Comment proceeding.

The ALAC made several suggestions to PIR regarding the issue of ISOC/PIR. The ALAC noted that PICs are the best mechanism with which to enshrine the essential characteristics of a .ORG registry, yet there are significant issues with PIC enforcement that need to be addressed for PICs to be considered a trustworthy assurance. They noted that from the standpoint of an "individual end user," a 10 annual price cap would add a lot of predictability. The ALAC also noted that the stewardship council for .ORG is a good start, but its mandate should be wider than just free speech and privacy, and suggested a few board seats reserved for 501c(3) organizations, chosen by the community, would be more powerful. Reserving certain seats to be selected by NPOC and perhaps the ALAC (to represent the individual registrants) would help a great deal.

The ALAC’s objective is to enshrine PIR's best practices in its contract with ICANN such that they survive any further transitions of ownership.

The ALAC congratulated the ICANN Finance and Planning team, as the draft plans and budget have shown great improvement over the past few years. Not only in how the information is provided, but in the way the plans and budget are structured. The ALAC made several suggestions with regards to the Operating & Financial Plan and Budget, emphasizing that there is not an exact correlation between the number of domains and the income of ICANN. This is important because ICANN relies upon the number of contracted registries and registrars and the number of domains a gTLD has.

The ALAC drafted a separate response to Appendix C, relating to the Evolution of the Multistakeholder Model, following their statement. The At-Large community registered its surprise and disappointment at seeing this important subject, which has been such a major topic of discussion, now relegated to an appendix in this Public Comment - in which it is unlikely to get the time and attention it deserves from the ICANN community.

While several Members of the ALAC Auction Proceeds team originally preferred Mechanism B - where ICANN worked with a non-profit organization already adept in the evaluation, selection and the allocation and distribution of grant funds - ALAC consensus was arrive at for Mechanism A. (Mechanism A allows outsourcing if viewed as advantageous, and in fact ICANN often outsources parts of its responsibilities which are not core to overseeing its Bylaw-mandated responsibilities. Thus Mechanism A could end up being comparable to Mechanism B, but provided more management flexibility in deciding how the varying aspects of the project would be carried out).

The ALAC notes that presumption of the independent panel, with no connection to or control by either ICANN Org or the ICANN Board (preferably contracted to a suitable non-profit or a set of experts in the field of grant selection and allocation) is a critical part of this decision and the ALAC would strongly object and withdraw its support if that condition changes.

An “At-Large Valentine”, regarding the Proposed Amendment 3 to the .COM Registry Agreement, written in good faith and good humor, was submitted to the ICANN Board on 13 February 2020. Jonathan Zuck, ALAC Vice Chair for Policy and CPWG Co-Chair, drafted the letter on behalf of At-Large. ALAC Members and At-Large community members reviewed and approved the letter during the CPWG meeting on Wednesday, 12 February 2020. 

The ALAC welcomed the LOI between Verisign and ICANN as a commitment to expand efforts to identify and promulgate best practices by contracted parties to mitigate DNS Abuse. While there are many whose efforts exceed those of others, the At-Large Community believes that even more can be done both in terms of best practices and in terms of bringing along those whose practices are not the best.

The ALAC noted that ICANN has been striving to be more inclusive in an effort to engage more volunteers with diverse backgrounds. ICANN acknowledges the difficulty in getting new people to join and engage within ICANN and to increase the diversity of participants. The Multistakeholder Model Work Plan takes note of the importance to ICANN to develop pathways to enable effective participation. One of the more practical ways for ICANN to facilitate participation is for ICANN Org, to be more aware of and to avoid clashing with important holidays and religious days observed by volunteers who work countless hours to improve ICANN’s multistakeholder advisory work. By avoiding these dates as much as possible it is showing all  volunteers that ICANN Org understands their concerns and does its best to avoid conflicts. 

The ALAC made several other suggestions regarding ICANN meeting dates in 2022 and from 2024-2028.

The ALAC noted the ATRT review has produced a considerable amount of work in little time and this is laudable. Nevertheless, from an end-user perspective, ATRT should consider deliberating the following questions: (1) How can ICANN better address conflicts of interest? The ICANN community is relatively small, with relatively few actors involved in the process. Conflicts of interest, perceived or real, can impact negatively on ICANN’s standing; (2) How can transparency be increased? (3) How can ICANN ensure that in cases where issues persist, processes are initiated to correct trajectory? (For example, if multiple reviews identify the same issue or if they find implementation to be lacking, how can this be fast-tracked transparently and effectively?) (4) Might it be necessary to “silo off” or ring-fence certain functions, including reviews, compliance, and other types of community oversight? (5) How can ICANN improve their responsiveness to community and review team questions and affairs, and what policies should be created to ensure these are dealt with? The ALAC also suggested taking several noted options into consideration, emphasizing from an end user perspective, more, not less, accountability and transparency is required from the ICANN community and org. 

Overall, the ALAC supports the suggested changes to the ICANN Public Comment, public input as well as the accountability indicators. We believe those changes would make the Public Comments more effective and show better transparency. We strongly believe that a wide, open and inclusive process should be maintained in policy development process especially with input representing the multistakeholder environment. Policy development must be transparent, efficient and should not be biased or skewed towards a group.

The ALAC noted the proposed sale of PIR to Ethos Capital has, understandably, created quite a stir, prompting commentary from many perspectives within the ICANN community, and applauds the efforts by the ICANN Board to clarify and make transparent, as much as possible, the process regarding the deal and to take the time to encourage the best possible result.

The ALAC Advice to the ICANN Board suggested (8) recommendations: (1) The Registry for .ORG must be organized as either a charitable non-profit [501c(3) in the US] or a “Benefit Corporation” (B Corporation); (2) One-third of the Registry Corporate Board must be representatives of charitable nonprofits; (3) One Board member selected by the ALAC; (4) The Registry for .ORG must enshrine in its bylaws that the principal focus of the domain is nonprofits and individuals and not commercial interests; (5) The Registry must enshrine in its bylaws a commitment to free speech and a resistance to takedown demands with a political basis; (6) The Registry must provide 6 months prior written notice to its registrants of any increase in wholesale price of their domain names registration renewal fees and the option of a 20-year renewal thereof at the pre-increase price; (7) The Registry Agreement must enshrine PIR prohibited practices such a bulk sales to commercial registrars; and (8) The Registry Agreement must establish a “DNS Abuse Ceiling”.

Background

Prior to ICANN66, At-Large and other community groups within ICANN identified the issue, released several reports on the topic of DNS Abuse. In advance of ICANN66, At-Large Consolidated Policy Working Group (CPWG) led by Co-Chairs Jonathan Zuck and Olivier Crépin-Leblond discussed recent DNS Abuse research and how DNS Abuse impacts the Internet end user community, including the erosion of trust and security. During ICANN66, At-Large organized a policy session on “DNS Abuse – End User Concerns”, with a panel presentation. Jonathan Zuck and Joanna Kulesza, ALAC Member, moderated the session and summarized how At-Large can enhance Internet end user protection against DNS Abuse. The ALAC drafted ALAC Advice on the topic during ICANN66, and finalized the draft in subsequent CPWG meetings. The ALAC Advice on DNS Abuse was submitted to the ICANN Board on 24 December 2019.

ALAC Advice

The ALAC made a series of (8) recommendations to the ICANN Board. The ALAC emphasized that community dialogue cannot delay or defer ICANN’s commitments or operations related to DNS Abuse. Their recommendations speak to the insufficiency of the status quo, and stressed their recommendations that no new round will be approved without substantial changes in the area of DNS Abuse. Please read the full advice here.

See related ALAC Final Response to the GNSO Questions on DNS Abuse (April 2022). 

As a worldwide internationally recognized humanitarian aid organization, and one that has been regularly the target of those seeking to fraudulently extract donations, the ALAC believes that the International Federation of Red Cross and Red Crescent Societies (incorporating National Red Cross or Red Crescent Societies, and the International Committee of the Red Cross) should be given the benefit of protection to its various identifiers, designations and/or acronyms as intended by the policy changes proposed for implementation in the said updated consensus policy. This includes the proposed action to recognize changes to the official names of the Red Cross Society entities, including component names, in Eswatini and Macedonia, respectively, an action we view as necessary.

The ALAC finds the report to include very useful information that should be used to guide the development of relevant policies, and appreciates the team's effort and supports the provided recommendations. 

The ALAC highlights the importance of the recommendations related to the accuracy of data, and it strongly advises its acceptance by the ICANN Board. In light of the GDPR, the ALAC noted the importance of several other recommendations in the WHOIS Report​ encouraging a more proactive position of contractual compliance, especially in regards to DNS Abuse, as well as the team's findings with regard to law enforcement needs.

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 a change is in process in the 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.

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 ICANN.org 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, ICANN.org 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, ICANN.org 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. 

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.  

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.

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.

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.

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.

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.

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

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.

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.

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.

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

Note: Not a formal ICANN Public Comment.

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: 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.