PLEASE NOTE Webinar relating to this matter => Listen to Recording => "To give a better idea of the progress made to date and an opportunity to answer questions from community members, there will be a webinar: The recordings of the Framework of Interpretation Webinar on Revocation today 12 November. Mp3 (audio recording) Adobe Connect Recording (visual recording including slides)=
Comment Close Date | Statement Name | Status | Assignee(s) and | Call for Comments | Call for Comments Close | Vote Announcement | Vote Open | Vote Reminder | Vote Close | Date of Submission | Staff Contact and Email | Statement Number |
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20.12.2013 | ccNSO FoI WG's Interim Report on "Revocation" | Adopted 14Y, 0N, 0A | Rinalia Abdul Rahim (APRALO) | 08.11.2013 | 10.12.2013 | 12.12.2013 | 12.12.2013 | 18.12.2013 | 19.12.2013 | 20.12.2013 | Bart Boswinkel bart.boswinkel@icann.org | AL-ALAC-ST-1213-02-00-EN |
Comment / Reply Periods (*)
(*) Comments submitted after the posted Close Date/Time are not guaranteed to be considered in any final summary, analysis, reporting, or decision-making that takes place once this period lapses.
FINAL VERSION TO BE SUBMITTED IF RATIFIED
Please click here to download a copy of the PDF below.
FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC
The ALAC congratulates the ccNSO Framework of Interpretation Working Group (FOIWG) on the outcome of its work to clarify the parameters governing the revocation of ccTLD delegation by the IANA Operator.
The ALAC strongly believes that clarity on revocation parameters as well as a clear and transparent process on the part of the IANA Operator are crucial to ensure that any act of revocation is carried out with accountability, transparency, sensitivity and care, and does not in any way disrupt the continued name resolution for Internet users.
The ALAC agrees with the Working Group’s interpretation of RFC 1591, which provides for revocation as one of three mechanisms available to the IANA Operator. We generally support the selected limits of revocation to cases where there are “persistent problems with the operations of the domain” and where there continues to be “substantial misbehavior” on the part of ccTLD managers despite the IANA Operator’s best efforts to stop the misconduct. We are also satisfied that the Working Group has defined what constitutes “persistent problems” and “substantial misbehavior” clearly to support appropriate action by the IANA Operator.
The Working Group indicated that it had considered whether the GAC Principles and accompanying guidelines are consistent with the RFC 1591 and whether they provide an aid to the Working Group’s interpretation (Section 2.2.2). We do not see any conclusion to these considerations. We note that section 4.3.7.2 appears to factor the GAC Principles in specifying that “If the IANA Operator revokes a delegation it should attempt, in collaboration with the significantly interested parties to ensure the ccTLD will continue to resolve names until a suitable replacement can take over.” As a form of good practice, we strongly recommend that the IANA Operator consult with the local government before taking action to revoke any ccTLD operator.
We further suggest the following to strengthen the interpretation work:
- Specify further the appeals mechanism for the ccTLD manager in the case of revocation in section 4.3.7.3. Operationalization of the interpretation would be more efficient if there is greater clarity on the type and geographic jurisdiction of the “independent body” that would qualify for the appeals process.
- Request the IANA to maintain accurate and informative reports on cases of re-delegation and to record receipts of delegation transfer consent from the incumbent ccTLD manager so as to better distinguish clear revocation cases when the IANA’s performance is reviewed.
With regard to the questions posed by the FOIWG to the community, our responses are as follows:
- Is the approach used by the working group satisfactory?
Yes. - Do the issues identified by the working group for this topic capture the major problems associated with the topic? If not what is missing?
Yes for cases that involve "operational problems" and "substantial misbehavior" on the part of the incumbent ccTLD Operator. One gap that is of concern to our community is the consideration of whether or not the IANA Operator is empowered to act in cases where there is a request for revocation from a local government, which is backed by local law, but where there are no "operational problems" and no "substantial misbehavior" on the part of the incumbent ccTLD Operator. Clarification on how such cases will be handled by the IANA Operator is requested. - Is the proposed interpretation of the relevant sections of RFC 1591 effective and supported?
Yes. - Are the proposed recommendations effective in addressing the concerns raised in the final report of the DRDWG regarding this topic?
Yes.
FIRST DRAFT SUBMITTED
The ALAC congratulates the ccNSO Framework of Interpretation Working Group (FOIWG) on its work to clarify the parameters governing the revocation of ccTLD delegation by the IANA Operator.
Clarity on the revocation parameters and process is crucial to ensure that any act of revocation on the part of the IANA operator is carried out with sensitivity and care, as a last resort, and does not in any way disrupt the continued name resolution for Internet users.
The ALAC agrees with the Working Group’s interpretation of RFC 1591, which provides for revocation as one of three mechanisms available to the IANA Operator. We support the selected limits of revocation to cases where there are “persistent problems with the operations of the domain” and where there continues to be “substantial misbehavior” on the part of ccTLD managers despite the IANA Operator’s best efforts to stop the misconduct. We are also satisfied that the Working Group has defined what constitutes “persistent problems” and “substantial misbehavior” clearly to support appropriate action by the IANA Operator.
In section 2.2.2 of its report, the Working Group indicated that it had considered whether the GAC Principles and accompanying guidelines are consistent with the RFC 1591 and whether they provide an aid to the Working Group’s interpretation. We do not see any conclusion to these considerations. However, we do note that section 4.3.7.2 appears to factor the GAC Principles in specifying that “If the IANA Operator revokes a delegation it should attempt, in collaboration with the significantly interested parties to ensure the ccTLD will continue to resolve names until a suitable replacement can take over.”
We further suggest the following to strengthen the interpretation work:
- Specify further the appeals mechanism for the ccTLD manager in the case of revocation in section 4.3.7.3. Operationalization of the interpretation would be more efficient if there is more clarity on the type and geographic jurisdiction of the “independent body” that would qualify for the appeals process.
- Request the IANA to maintain accurate and informative reports on cases of re-delegation and to record receipts of delegation transfer consent from the incumbent ccTLD manager so as to better distinguish clear revocation cases when reviewing the IANA’s performance.
With regard to the questions posed by the FOIWG to the community, our responses are as follows:
- Is the approach used by the working group satisfactory?
Yes.
- Do the issues identified by the working group for this topic capture the major problems associated with the topic? If not what is missing?
Largely yes. See the ALAC’s comment in the section above for gaps.
- Is the proposed interpretation of the relevant sections of RFC 1591 effective and supported?
Yes.
- Are the proposed recommendations effective in addressing the concerns raised in the final report of the DRDWG regarding this topic?
Yes.
15 Comments
Rinalia Abdul Rahim
DRAFT ALAC Statement on Revocation of ccTLD Delegation by the IANA Operator
The ALAC congratulates the ccNSO Framework of Interpretation Working Group (FOIWG) on its work to clarify the parameters governing the revocation of ccTLD delegation by the IANA Operator.
Clarity on the revocation parameters and process is crucial to ensure that any act of revocation on the part of the IANA operator is carried out with sensitivity and care, as a last resort, and does not in any way disrupt the continued name resolution for Internet users.
The ALAC agrees with the Working Group’s interpretation of RFC 1591, which provides for revocation as one of three mechanisms available to the IANA Operator. We support the selected limits of revocation to cases where there are “persistent problems with the operations of the domain” and where there continues to be “substantial misbehavior” on the part of ccTLD managers despite the IANA Operator’s best efforts to stop the misconduct. We are also satisfied that the Working Group has defined what constitutes “persistent problems” and “substantial misbehavior” clearly to support appropriate action by the IANA Operator.
In section 2.2.2 of its report, the Working Group indicated that it had considered whether the GAC Principles and accompanying guidelines are consistent with the RFC 1591 and whether they provide an aid to the Working Group’s interpretation. We do not see any conclusion to these considerations. However, we do note that section 4.3.7.2 appears to factor the GAC Principles in specifying that “If the IANA Operator revokes a delegation it should attempt, in collaboration with the significantly interested parties to ensure the ccTLD will continue to resolve names until a suitable replacement can take over.”
We further suggest the following to strengthen the interpretation work:
With regard to the questions posed by the FOIWG to the community, our responses are as follows:
Yes.
Largely yes. See the ALAC’s comment in the section above for gaps.
Yes.
Yes.
END
Evan Leibovitch
Two questions regarding the real-world outcomes of this work:
Eduardo Diaz
Evan:
I am preparing some comments to add to this statement if we all agree. These are based on the experiences that we had with the IANA processes and their interpretation of the RFC1591 when the Internet Society of Puerto Rico submitted a re-delegation request for .pr. In our case, we were requesting a revocation based on the support from "significantly interested parties" which included the local Internet community of end-users, major businesses and business organizations and the government.
Eduardo Diaz
The FOIWG makes it very clear in section 4.3.5.3 that any ccTLD revocation by the IANA operator should be based EXCLUSIVELY on the competence and behavior of the ccTLD manager with respect to the stability and security of the DNS and/or the continuing operation of the domain.
The Internet Society of Puerto Rico (ISOCPR) and representatives from the government of Puerto Rico were given the run around by the IANA operator during the failed re-delegation of the .pr because the IANA operator did not clearly define the parameters required for a re-delegation request (or a revocation for that matter) based on the lack of equitable, honestly and competence by the ccTLD manager. This resulted in wasted efforts by parties, misunderstandings and poverty of transparency through the whole process. Having known this interpretation from the beginning we would have done things differently. ISOCPR is very pleased to see that these issues are being tackled finally.
Eduardo Diaz
I suggest to change the second paragraph to read as follows:
---
The ALAC strongly believes that clarity on the revocation parameters and a clear and transparent process on the part of the IANA operator is crucial to ensure that any act of revocation is carried out with transparency, understanding, sensitivity and care and does not in any way disrupt the continued name resolution for Internet users.
---
Change answer in question #2 to the following:
---
Yes. Missing is a clear interpretation for the case where a government requests a revocation without the ccTLD manager consent.
---
Revise the formating in the questions lists.
Rinalia Abdul Rahim
REVISED ALAC Statement on Revocation of ccTLD Delegation by IANA Operator
The ALAC congratulates the ccNSO Framework of Interpretation Working Group (FOIWG) on its work to clarify the parameters governing the revocation of ccTLD delegation by the IANA Operator.
The ALAC strongly believes that clarity on the revocation parameters and a clear and transparent process on the part of the IANA operator are crucial to ensure that any act of revocation is carried out with transparency, understanding, sensitivity and care, and does not in any way disrupt the continued name resolution for Internet users.
The ALAC agrees with the Working Group’s interpretation of RFC 1591, which provides for revocation as one of three mechanisms available to the IANA Operator. We support the selected limits of revocation to cases where there are “persistent problems with the operations of the domain” and where there continues to be “substantial misbehavior” on the part of ccTLD managers despite the IANA Operator’s best efforts to stop the misconduct. We are also satisfied that the Working Group has defined what constitutes “persistent problems” and “substantial misbehavior” clearly to support appropriate action by the IANA Operator.
In section 2.2.2 of its report, the Working Group indicated that it had considered whether the GAC Principles and accompanying guidelines are consistent with the RFC 1591 and whether they provide an aid to the Working Group’s interpretation. We do not see any conclusion to these considerations. However, we do note that section 4.3.7.2 appears to factor the GAC Principles in specifying that “If the IANA Operator revokes a delegation it should attempt, in collaboration with the significantly interested parties to ensure the ccTLD will continue to resolve names until a suitable replacement can take over.”
We further suggest the following to strengthen the interpretation work:
(1) Specify further the appeals mechanism for the ccTLD manager in the case of revocation in section 4.3.7.3. Operationalization of the interpretation would be more efficient if there is more clarity on the type and geographic jurisdiction of the “independent body” that would qualify for the appeals process.
(2) Request the IANA to maintain accurate and informative reports on cases of re-delegation and to record receipts of delegation transfer consent from the incumbent ccTLD manager so as to better distinguish clear revocation cases when reviewing the IANA’s performance.
With regard to the questions posed by the FOIWG to the community, our responses are as follows:
(1) Is the approach used by the working group satisfactory?
Yes.
(2) Do the issues identified by the working group for this topic capture the major problems associated with the topic? If not what is missing?
Yes. Gaps include a clear interpretation for the case where a government requests a revocation without the incumbent ccTLD manager’s consent.
(3) Is the proposed interpretation of the relevant sections of RFC 1591 effective and supported?
Yes.
(4) Are the proposed recommendations effective in addressing the concerns raised in the final report of the DRDWG regarding this topic?
Yes.
END
Anonymous
Eduardo Diaz
In the context of revocations I do not consider the government to be a stakeholder. The interpretation is very clear that if any stakeholder requests a revocation for whatever reason without the ccTLD manager consent it will be pushed back to the local level to be resolved. However the interpretation is not clear in the case when the government of a country requests a revocation for whatever reasons without the consent of the ccTLD manager. It is not clear if IANA will be obligated to do it or send it back to be resolved locally.
Jacqueline Morris
Carlton Samuels
Should a revocation request from government be given extra scrutiny or not? If so, should there not be a higher threshold for a revocation request originating from the govt. to prevail?
Carlton
Eduardo Diaz
Whatever the processes or requirements are, the interpretation should be very clear for this specific case. Will this type of case be sent back if there is no ccTLD manager consent attached to it?
Jacqueline Morris
Eduardo Diaz
The point is that revocation without the ccTLD manager consent is being interpreted by the WG for cases where the manager is seriously and persistently in breach of technical abilities to resolve its domains. It does not interpret a revocation when a government has a mandate for revocation without the ccTLD manager consent for any cause other than the ccTLD manager technical abilities. The applicability of "local law" within the context of revocation in the RFC 1591 should be clearly interpreted by the WG to cover cases like this.
Anonymous
"Revocation" is a component in the whole Framework of Interpretation (FoI) structure and should be viewed in the framework. It is the very last resort--a kill switch-to act on. Before moving to IANA for action, all the "significantly" interested stakeholder groups should have been involved, consulted and voiced. The interpretation of "local law" should have been done before this step, rather than being referred back from IANA to local authority upon revocation. Hong
Eduardo Diaz
Hong Xue
I am not sure I understand your comment with regards to the "interpretation of local law". As far as I know the framework of interpretation WG has not interpreted the applicability of "local law" within the context of revocation in the RFC 1591. The question still stands: if a government with a mandate to revocate without the ccTLD manager consent for whatever cause other than technical competence will it be sent back to be resolved locally by the IANA operator?