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06.09.2015Next-Generation gTLD Registration Directory Services to Replace WHOIS Preliminary Issue ReportADOPTED 11Y, 0N, 0ACarlton Samuels    

 23:59 UTC

 
Marika Konings
AL-ALAC-ST-0915-01-00-EN


For information about this Public Comment, please click here 

 

FINAL VERSION TO BE SUBMITTED IF RATIFIED

Click here to download the document below.



FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC

ALAC Statement on the Next-Generation gTLD Registration Directory Services to Replace WHOIS Preliminary Issue Report 

The ALAC strongly supports the research and recommendations in the Preliminary Issue Report. We are particularly impressed by the report’s clear, coherent summary of the milestone policy development activities, studies, and implementation efforts pertaining to WHOIS.

WHOIS is and remains a priority issue of focus for the ALAC and our engagement in WHOIS policy development activities has been extensive and profound throughout the years. The ALAC has formed the following position and wishes to reiterate: Before creating any new policy framework for a next-generation Registration Directory Services (RDS) to replace the legacy WHOIS system, the fundamental questions regarding the purposes, uses, collection, maintenance, and provision of registration data must be addressed. The ALAC is pleased to see that the report concurs with our long-held position. 

The ALAC supports the proposed Policy Development Process (PDP) as a whole, including the ICANN staff recommended 3-phase approach for organizing the work. Specifically, “the proposed issue raised for consideration” (2.2.a.), which concerns the fundamental questions about WHOIS, will point this Board-initiated PDP WG in the right direction to start its work. Furthermore, the ALAC strongly agrees with the ICANN staff recommendation that the PDP should proceed only after careful consideration of the recommendations by the Expert Working Group on gTLD Registration Directory Services (EWG). The EWG Final Report enumerates several inter-related WHOIS policy concerns, and the PDP needs to move the EWG process forward by analyzing the fundamental elements, purposes, and requirements of the gTLD registration data in order to determine if and why a next-generation RDS is needed to replace WHOIS. We too endorse the notion that a successful outcome of this PDP is important to resolve a multitude of problems identified in the legacy WHOIS system.

The implementation of the PDP’s proposed Process Framework will be of heightened interest to the ALAC. The ALAC hopes and trusts that sufficient measures will be put in place to ensure equitable and representative participation of all stakeholders in the PDP, where members consider all views and are willing to forge consensus.

End user community engagement in this PDP is a major concern. The ALAC believes that this critical subject needs broad community inputs and requires extraordinary measures to ensure high level of multi-stakeholder participation. While the Draft Charter indicates that the PDP WG will be “open to all interested [parties],” the long-term time commitment that this PDP demands – not only within the overall PDP WG but also in the series of sub-groups that the 3-phase process may potentially create – can hinder equitable participation. The ALAC is concerned that volunteers from the end user community, whose participation is only possible by carving out time away from work and life commitments, will face extraordinary challenges. From our experience, the complex issues in this PDP will almost certainly require face-to-face meetings of the PDP WG and future sub-groups, and this will impose financial constraints to the participation of end user volunteers. As a consequence, the end user voice may very well be stifled by the voices of interested parties who participate in the PDP as part of their jobs in support of their business needs and receive assistance from their organizations.

The ALAC will be vigilant to ensure that measures to enable the broadest participation in the PDP WG and sub-groups are considered and implemented.

 


FIRST DRAFT SUBMITTED

ALAC Statement on the Next-Generation gTLD Registration Directory Services to Replace WHOIS Preliminary Issue Report 

The ALAC strongly supports the research and recommendations in the Preliminary Issue Report. We are particularly impressed by the report’s clear, coherent summary of the milestone policy development activities, studies, and implementation efforts pertaining to WHOIS.

WHOIS is and remains a priority issue of focus for the ALAC and our engagement in WHOIS policy development activities has been extensive and profound throughout the years. The ALAC has formed the following position and wishes to reiterate: Before creating any new policy framework for a next-generation Registration Directory Services (RDS) to replace the legacy WHOIS system, the fundamental questions regarding the purposes, uses, collection, maintenance, and provision of registration data must be addressed. The ALAC is pleased to see that the report concurs with our long-held position. 

The ALAC supports the proposed Policy Development Process (PDP) as a whole, including the ICANN staff recommended 3-phase approach for organizing the work. Specifically, “the proposed issue raised for consideration” (2.2.a.), which concerns the fundamental questions about WHOIS, will point this Board-initiated PDP WG in the right direction to start its work. Furthermore, the ALAC strongly agrees with the ICANN staff recommendation that the PDP should proceed only after careful consideration of the recommendations by the Expert Working Group on gTLD Registration Directory Services (EWG). The EWG Final Report enumerates several inter-related WHOIS policy concerns, and the PDP needs to move the EWG process forward by analyzing the fundamental elements, purposes, and requirements of the gTLD registration data in order to determine if and why a next-generation RDS is needed to replace WHOIS. We too endorse the notion that a successful outcome of this PDP is important to resolve a multitude of problems identified in the legacy WHOIS system.

The implementation of the PDP’s proposed Process Framework will be of heightened interest to the ALAC. The ALAC hopes and trusts that sufficient measures will be put in place to ensure equitable and representative participation of all stakeholders in the PDP, where members consider all views and are willing to forge consensus.

End user community engagement in this PDP is a major concern. The ALAC believes that this critical subject needs broad community inputs and requires extraordinary measures to ensure high level of multi-stakeholder participation. While the Draft Charter indicates that the PDP WG will be “open to all interested [parties],” the long-term time commitment that this PDP demands – not only within the overall PDP WG but also in the series of sub-groups that the 3-phase process may potentially create – can hinder equitable participation. The ALAC is concerned that volunteers from the end user community, whose participation is only possible by carving out time away from work and life commitments, will face extraordinary challenges. From our experience, the complex issues in this PDP will almost certainly require face-to-face meetings of the PDP WG and future sub-groups, and this will impose financial constraints to the participation of end user volunteers. As a consequence, the end user voice may very well be stifled by the voices of interested parties who participate in the PDP as part of their jobs in support of their business needs and receive assistance from their organizations.

The ALAC will be vigilant to ensure that measures to enable the broadest participation in the PDP WG and sub-groups are considered and implemented.

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6 Comments

  1. First thing, in the business that sustains me, you do well by recognizing exceptional skills.  Kudos to Marika Konigs for an excellent piece of writing for this Preliminary Issues Report. it is altogether cogent even as it covers every angle yet remains laudably readable.  And for this subject matter, that ain't easy!

    Some may recall I've always felt that in the complement of senior ICANN policy staff I have been privileged to work with, I hold that Margie Milam and Robert Hoggarth to be worth every penny they bill ICANN. Add Marika Konings to this list. They listen well, have excellent analytical skills and are superlative writers.

    That said, I think an ALAC Statement that endorses the recommendations of the report and note concerns on the Draft WG Charter be entered.  I have crafted the following for consideration:

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    The ALAC reiterates its long-held position that any policy framework effecting a new dispensation for gTLD Registration Data Directory Services can only happen when the fundamental questions are answered.

    We hold that the tasking question for the Board-initiated GNSO PDP WG as constructed is the optimal point of departure for its work:  the “Analysis of the purpose of collecting, maintaining and providing access to gTLD registration data and consider safeguards for protecting that data, determining if and why a next-generation Registration Directory Service (RDS) is needed to replace WHOIS, and creating policies and coexistence and implementation guidance to meet those requirements.

    The ALAC is further seized of the fact that a ‘successful outcome of the PDP is important to resolve a multitude of concerns surrounding gTLD registration data’ and the problems of the legacy WHOIS. 

    The ALAC notes the several inter-related policy concerns acknowledged in the EWG’s Final Report and enumerated by the Issues Report and concurs with the ICANN staff recommendation “that the PDP proceed by considering carefully the recommendations of the EWG and work to create a new policy framework for a next-generation RDS to replace WHOIS.

    The ALAC endorses the ICANN staff recommendation for the PDP to utilize the EP-WG’s 3-phase process as defined in the published Process Framework to “structure a PDP Working Group in a manner that is not only consistent with PDP Rules but facilitates substantive and timely progress on the complex set of inter-related questions that must be addressed by the PDP.”

    Finally, the ALAC believes that this subject requires and must even take extraordinary measures to ensure that the broadest community input and participation is enabled. So while we note the Draft WG charter leaves participation ‘open to all interested parties’, we are concerned that with the commitment of time this PDP will draw, end user participation may very well be stifled by the voice of interested parties who participate as a routine part of their jobs. We hope and trust sufficient safeguards will be adopted to ensure equality of access, for contention and for sober consideration for all views.

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    -Carlton 

    1. Carlton, as I read youyour suggested ALAC comment, it

      • Supports what is in the Preliminary IR;
      • Emphasizes several aspects that we agree with but want to highlight;
      • Has the sole concern that this is a big piece of work, and that equitable and representative participation from those with less "skin-in-th-game" may be problematic,

      Is that an accurate summary?

      1. Yessir, summary is accurate.

        The At-Large has always had priorities in WHOIS and we should emphasize those; we did that.

        Yes, At-Large participation in the series of WGs that are expected via the roadmap proposed for the PDP is a major concern. These will not be easy; I suspect they will be mini EWGs in the execution. SO how they are implemented and provisioned will be of great interest for us. For example, when f2f meetings of the WGs are required and our members must participate + the long-term commitment for time required.

         

        -Carlton

  2. When I admitted Marika to my pantheon of ICANN staff policy development heroes, I inadvertently left out a lady named Lisa Phifer. I don't think she's yet a direct staff but Marika has acknowledged that she was instrumental in getting that report done. I know Lisa from her engagement in assisting the work of the EWG.  She was particularly brilliant in shadowing the sub-teams examining the details of vexed issues like privacy, national jurisdiction and obligations, access rights and so on in that exercise. Most of all, she is brilliant at manufacturing consensus. Here's why.

    Lisa is an exceptional listener and can pick up a nuanced view better than most everybody I have ever worked with. She is respectful of all views, have the best attitude when smoking out unsaid reservations and best of all, finding that point of intersection. Then she goes to crafting the resulting ellipsis that will join two arguments for the win. Win-Win and Win.

    Lisa knows I admire her craft and skills. As a knowledge worker in the policy and strategy development domain, I cannot resist noting and acknowledging talent for this kind of work when I see it.  I will sign up for any team she's on if only for the subdued delight of working with the best. 

    -Carlton

  3. I agree with Carlton's proposed response.

    The Report itself is huge, but is largely a collection of all of the work/report/recommendations relating to Whois.  What we need now is for the EWG process to move forward, starting where the report suggests: a long look at Whois data, what are its elements, why are they collected (and do they need to be), what elements should remain private, and under what circumstances can those data elements be published - only to an individual or available generally.  And that is what this proposed PDP will do.  So with Carlton's suggestions, ALAC should support the report and the proposed PDP process

  4. I also agree with Carlton's proposed response.

    I'd also like to put it in the record that I am glad this process, with all its goods/bads, is actually moving forward. The WHOIS review process has become embroiled with such history and has such limitations that we end up putting a plaster on a wooden leg. The opportunity to start fresh is very welcome and it is a pity that ICANN has apparently so far dragged its feet about it.