DRAFT v1 16 January 2019
The At-Large Advisory Committee (ALAC) is the primary organizational home for the voice and concerns of the individual Internet end user.
Below is a compilation of executive summaries of ALAC policy comments & advice since ICANN60, providing the Internet end user perspective of ICANN policy.
ALAC Statement Definitions
» Comment is an ALAC statement providing input and feedback in the ICANN public comment process. Public comment is a key part of the policy development process (PDP), allowing for refinement of recommendations before further consideration and potential adoption. Public Comment is also used to guide implementation work, reviews, and operational activities of the ICANN organization.
» Advice is an ALAC statement issued to the ICANN Board as formal advice, representing the interests of the Internet end user community.
» Correspondence is all formally drafted, signed communications pertaining to non-confidential topics within ICANN’s remit and that are directed to the ICANN Board, CEO, Executives or staff.
References
» ICANN Multistakeholder Advice Development
| Date Submitted to ICANN Public Comment | ALAC Statement | Executive Summary |
|---|---|---|
| Application for New Uniform Domain Name Dispute Resolution Policy (UDRP) Dispute-Resolution Service Provider | The ALAC strongly supports the proposal for a new UDRP Dispute Resolution Provider, viewing it beneficial to the interests of all Internet end users, particularly to domain name registrants. |
| Initial Report of the Expedited Policy Development Process (EPDP) on the Temporary Specification for gTLD Registration Data Team | The ALAC submitted a Word Doc form mirroring the new Google Form requested by the EPDP Team for collection of this public comment. In its statement, the ALAC provided its answers on the questions posed by the EPDP Team. In particular, the ALAC made recommendations on additional purposes for processing registration data, including the Accuracy Reporting System (ARS) and research and threats analysis/prevention from the Office of the Chief Technology Officer (OCTO). Regarding data elements, the ALAC noted Registrant provided data must not be unilaterally removed without due consultation with the data provider, and the registrant must declare whether it is a natural or legal person. The ALAC noted the technical contact fields must be mandatory, and the Organization field should not be redacted. The ALAC also noted in its conclusion the SSAC revised version of SAC101, a paper previously supported by ALAC, drawing particular attention to the statement, "RDDS access must comply with the law, but access should not be less timely, more restricted and less public than law requires." |
| 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. The ALAC also notably does not support a total ban of all forms of private resolutions, but we is strongly in favor of disallowing forms of private resolutions, detailed in the ALAC statement. |
| Proposed Consensus Policy on Protections for Certain Red Cross and Red Crescent Names in All Generic Top-Level Domains | The ALAC continues to take the position that as a humanitarian organization, and one that has been regularly the target of those seeking to fraudulently attract donations, the Red Cross should be afforded the courtesy of having its various identifiers protected at the second level in gTLD domain names. The ALAC cited its June 2018 statement of support for the Initial Report on the Protections for Certain Red Cross Names in all gTLDs – Policy Amendment Process, and affirmed support for the Reconvened WG's recommendations on proposed amendments. |
| Competition, Consumer Trust, and Consumer Choice Review Team (CCT) Final Report & Recommendations | As the principal voice of Internet end users within the ICANN community, the ALAC were interested in the findings and recommendations from the CCT Review, particularly in the areas of Choice and Trust. The ALAC is supportive of all of the recommendations in the Report, including the new ones relating to DNS abuse in New gTLDs. The ALAC reiterated they do not share a sense of urgency when it comes to subsequent procedures, but instead believe the community should address all of the deficiencies in the 2012 program before accepting additional applications. The ALAC commented on additional sections of the Report and Recommendations, including Recommendations 1, 8-10, 11-13, 14-25, 29-31, 32, 33 and 34-35. |
| Initial Report of the New gTLD Auction Proceeds Cross-Community Working Group | The ALAC have been following this issue closely, and discussed the issues internally prior to the issuance of the Initial Report. The ALAC discussed each of these mechanisms among the participants and members of the working group, and in their statement commented on Recommendations 1-10, noting it believes strongly that At-Large Structures (ALSes) and Individual members should be able to apply for funds; the proceeds from past auctions were intended for use in capacity building activities enhancing the mission of ICANN and consistent with one of its core principles for an “open and interoperable Internet”, for the benefit of the Internet community. |
| 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. |
| Registration Directory Service (RDS-WHOIS2) Review Team Draft Report of Recommendations | The primary concern for the ALAC in the RDS-WHOIS2 Review is the accuracy of registrant data (WHOIS data) and its use by security and law enforcement bodies in addressing the misuse and abuse of the DNS system. The ALAC summarized their positions on the 16 Recommendations under Objective 1, as well as Objectives 3, 5, 6 and the ICANN Bylaws. |
| ICANN Seeking Community Feedback on Proposed Unified Access Model | The ALAC cited their prior statement from 10 April 2018 relating to the access of WHOIS, and offered (4) general comments on the proposed UAM: (1) Any access model must be compliant with the GDPR, and ICANN should obtain legal advice from expert counsel to confirm compliance; (2) Internet end user rights should be part of the calculus, including knowledge of email sender identity, et al; (3) The UAM design should be scalable and not overly-reliant upon manual updates, and should have a well-defined taxonomy of abuse types, et al. Once an agreed upon set of inputs and outcomes is established, an automated system may be created to respond to WHOIS requests; (4) The various harms taken into account when considering the UAM must be done so in a non-biased fashion. |
| Draft PTI and IANA FY20 Operating Plan and Budgets | After consultations with the ICANN Finance Department and ALAC Finance and Budget Subcommittee (FBSC), the ALAC submitted comment on (4) sections of the Draft PTI and IANA FY20 Operating Plan and Budgets, including the Executive Summary, PTI Services Financial Overview, PTI Services Overview and PTI Services and Operating Plan. |
| Note: submitted to ICANN Board as ALAC Advice; ratified during ICANN63. | In its follow up to the joint statement, the ALAC and GAC agreed in the context of the Information Transparency Initiative (ITI) that clear and up-to-date information (from ICANN) to facilitate quick understanding of relevant issues and high interest topics is key for inclusive, informed and meaningful participation by all stakeholders, including non-experts – as, in the context of the IANA transition process – ICANN was able to offer timely and comprehensible information by breaking down complex issues into understandable components, which allowed interaction within the entire community. The ALAC and the GAC ask from ICANN that the same level of effort be made and the same service be provided to the community concerning information on all other relevant issues. |
| Proposed gTLD-Registration Data Access Protocol (RDAP) Profile | The ALAC recommends that ICANN adopt the RDAP quickly and effectively because they hold it is an essential step for ICANN to deploy a tiered-access model adequately. In addition, the ALAC recommends that ICANN address 5 ambiguities in the RDAP that are also present in the European Union's (EU) General Data Protection Regulation (GDPR), noting them in the statement. |
| Next Steps on Reviews | The ALAC supports the proposed path forward for the ATRT3, while stating the consideration of how to streamline specific reviews to make them more effective and impactful is a low priority item for ATRT3. The ALAC encourages active community participation in formulating any recommendations in organizational reviews, and states that specific reviews operating standards should take a minimalist approach. |
| 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. |
| Recommendations for Managing IDN Variant Top-Level Domains | The ALAC believes the main challenge while integrating IDN variant top-level domains is to balance positive user experience while ensuring the security, stability and manageability of the DNS. The ALAC provided advice on (4) questions posed by ICANN regarding the issue, and in general believes strict adherence to the Root Zone LGRs are the most appropriate way of arriving at IDN variant labels. |
| Draft ICANN Africa Strategic Plan 2016-2020 Version 3.0 | The ALAC recommended (1) an increased number of African ICANN staff to be seriously considered in the Draft Africa Strategic Plan; (2) involving more African participation in strategy planning and implementation; (3) local capacity building; (4) increased representation of African stakeholders in the SOs and ACs in addition to the ALAC and GAC. The ALAC also noted criteria for implementation should be further developed, and offered collaboration with the African community in At-Large. |
| 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). |
