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Proposed Implementation of GNSO Thick Whois Consensus Policy Requiring Consistent Labeling and Display of RDDS (Whois) Output for All gTLDs Follow Updates

ADOPTED 11Y, 0N, 0A

Main Penholder: Alan Greenberg

Assisted by: Holly Raiche Carlton Samuels

     
Krista Papac
krista.papac@icann.org
AL-ALAC-ST-0116-02-00-EN

For information about this Public Comment, please click here 

 

Brief Overview

Purpose: The public comment proceeding seeks to obtain community input on the proposed implementation of the Generic Names Supporting Organization (GNSO) Thick Whois Policy Development Process (PDP) recommendation, approved by the ICANN Board, requiring the consistent labeling and display of Whois Output for all gTLDs.

Current Status: The Thick Whois PDP Working Group delivered its Final Report [PDF, 1.23 MB] to the GNSO Council on 21 October 2013. The GNSO Council adopted the report and its recommendations on 31 October 2013. The ICANN Board adopted the recommendations of the Thick Whois PDP Working Group on 7 February 2014.

ICANN staff, in conjunction with the Implementation Review Team (IRT) worked together to develop a Draft Thick RDDS (Whois) Consensus Policy [PDF, 360 KB] addressing one of the two expected outcomes of PDP Recommendations: the consistent labeling and display of Whois ouput for all gTLDs. Community input is now sought on the Draft Thick RDDS (Whois)Consensus Policy [PDF, 360 KB] to ensure that the proposed implementation meets the intent of the relevant policy recommendation.

It should be noted that at this time ICANN staff and the IRT are still working on the second expected outcome of the implementation of the Thick Whois PDP: the transition from thin to thick Whois for .COM, .NET, and .JOBS.

Next Steps: ICANN staff will review the comments received in collaboration with the Implementation Review Team to determine whether any changes need to be made to the proposed implementation as a result of the input received. Subsequently, the current Draft Thick RDDS (Whois) Consensus Policy will be finalized and the implementation effective date will be announced. In addition, education and outreach materials will be prepared to accompany the implementation.

Section I: Description, Explanation, and Purpose

On 7 February 2014, the ICANN Board adopted GNSO consensus policy recommendations regarding the use of “thick" Whois by all gTLD registries. In consultation with the GNSOImplementation Review Team (IRT), which was formed as directed by the GNSO Council to work with ICANN staff to ensure that the resultant implementation fulfills the intentions of the approved policy recommendations, ICANN staff has identified two expected outcomes in the PDPrecommendations:

  • The consistent labeling and display of Whois output for all gTLDs (originating from Recommendation #1)
  • The transition from thick to thick for .COM, .NET, and .JOBS (originating from Recommendations #1 and Recommendation #3)

This Public Comment Period focuses on the proposed implementation of Recommendation #1 concerning the consistent labeling and display of Whois output for all gTLDs. Recommendation #1 of the Thick Whois PDP Final Report states: "The provision of thick Whois services, with a consistent labeling and display as per the model outlined in specification 3 of the 2013 RAA, should become a requirement for all gTLD registries, both existing and future."

To date, ICANN staff in collaboration with the IRT has taken the following steps to guide the implementation of Recommendation #1:

  • Conducted an Impact Assessment [PDF, 659 KB] and Detailed Analysis [XLSX, 98 KB] of the Consistent Labeling and Display requirement for all gTLDs
  • Proposed a synchronized implementation of this requirement with the roll out of RDAP in order to minimize impact on affected parties by allowing potential economies of scale in development efforts
  • Proposed a phased approach to the implementation in order to synchronize implementation with work ongoing at IETF on EPP Extensions that are necessary for part of this implementation
  • Created a Draft Thick RDDS (Whois) Consensus Policy and relevant Implementation Notes, which address implementation of the consistent labeling and display outcome.

ICANN staff and the GNSO Implementation Review Team are now looking for input on the implementation proposal contained in the Draft Thick RDDS (Whois) Consensus Policy [PDF, 360 KB], which aims to satisfy the intent of the relevant GNSO Policy Recommendation.

The Draft Thick RDDS (Whois) Consensus Policy [PDF, 360 KB] subject to this Public Comment period is composed of Consensus Policy language and Implementation Notes.  Three phases of implementation are described:

  • Phase 1: All gTLDs, excluding .COM, .NET and .JOBS, are required to display a  Registration Data Directory Services (RDDS) output compliant with this Consensus Policy, with the exception of Registrar Registration Expiration Date and Reseller information.
  • Phase 2: All gTLDs, excluding .COM, .NET and .JOBS, are required to display a Registration Data Directory Services (RDDS) output fully compliant with this ConsensusPolicy.
  • Phase 3: All gTLDs, including .COM, .NET and .JOBS, are required to provide a thick Registration Data Directory Services (RDDS) fully compliant with this Consensus Policy.

Please note that Phase 3 above is only referenced for informational purposes. It is not in the scope of this public comment proceeding as ICANN staff and the IRT are still discussing the implementation of the transition from thin to thick Whois for .COM, .NET and .JOBS (see Section IV: Additional Information).

Regarding Phase 1 and Phase 2, the public is invited to provide specific comments on how specialized Whois related provisions of the .CAT, .NAME, and .TEL Registry Agreements interact with the new requirement to have Consistent Labeling and Display (please refer to section 1.4.3 and 2.5 of the Draft Consensus Policy).

As a complement to reviewing the Draft Consensus Policy subject to this Public Comment period, commenters may also be interested in reviewing the Impact Assessment [PDF, 659 KB]ICANN staff completed and discussed with the IRT, and particularly the detailed analysis [XLSX, 98 KB] of impact on the Whois output of all gTLDs.

Section II: Background

ICANN specifies Whois service requirements through Registry Agreements (RAs) and the Registrar Accreditation Agreement (RAA) for the generic top-level domain (gTLD) registries. Registries have historically satisfied their Whois obligations under two different models. The two models are often characterized as "thin" and "thick" Whois registries.

This distinction is based on how two distinct sets of data are maintained. WHOIS contains two kinds of data about a domain name:

  • one set of data is associated with the domain name (this information includes data sufficient to identify the sponsoring registrar, status of the registration, creation and expiration dates for each registration, name server data, the last time the record was updated in the Registry database, and the URL for the registrar's Whois service),
  • a second set of data that is associated with the registrant of the domain name.

In a thin registration model the Registry only collects the information associated with the domain name from the Registrar. The Registry in turn publishes that information along with maintaining certain status information at the Registry level. Registrars maintain data associated with the registrant of the domain and provide it via their own Whois services, as required by Section 3.3 of the RAA for those domains they sponsor.

In a thick registration model the Registry collects both sets of data (domain name and registrant) from the Registrar and in turn publishes that data via Whois.

The Thick Whois PDP Working Group was tasked to provide the GNSO Council with a policy recommendation regarding the use of 'thick' Whois by all gTLD Registries, both existing and future.

As part of its deliberations on this issue, the PDP WG considerations included the following elements (among many others):

  • Whois Response consistency
  • Accessibility of Whois information by consumers, intellectual property owners and other users of Whois data
  • Cost implications for contracted parties
  • Impact of synchronization/migration on registries and registrars WHOIS and EPP systems
  • Competition in registry services
  • Existing Whois Applications

For additional information on the Background of the Thick Whois PDP Recommendations, please refer to the Thick Whois PDP Final Report [PDF, 1.23 MB].

Section III: Relevant Resources

Section IV: Additional Information

ICANN staff and the GNSO Implementation Review Team (IRT) are still discussing implementation of the second expected outcome of the Thick Whois PDP: the transition from thin to thick for .COM, .NET, and .JOBS. Implementation of this part of the Thick Whois PDPRecommendation will be addressed when an implementation path is identified and agreed upon with the IRT. Details of the Implementation plan are anticipated to be provided in a future revised version of the Thick RDDS (Whois) Consensus Policy Document, as appropriate.

Section V: Reports

Staff Contact

Krista Papac
krista.papac@icann.org

 

FINAL VERSION TO BE SUBMITTED IF RATIFIED

Click here to download the PDF below. 


FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC

The timeline for the “Thick Whois” PDP was:

  • The GNSO requested the Issue Report in September 2011;
  • The PDP was initiated by the GNSO in March 2012;
  • The Final Report was issued in October 2013;
  • The Board approved the PDP Recommendations in February 2014.

Although the PDP Charter allowed and in fact required consideration of a number of issues, the main question being asked was whether all gTLD registries should be required thick Whois services (now Registration Data Directory Services - RDDS). The prime recommendation of the PDP is that “The provision of thick Whois services, with a consistent labeling and display as per the model outlined in specification 3 of the 2013 RAA1, should become a requirement for all gTLD registries, both existing and future.”

The Implementation Plan published on 25 November 2015 and the subject of this Public Comment outlines a three phase process to implement the PDP recommendations, “each with a specific scope and a dedicated timeline”. These are:

  • Phase 1 - Effective Date: 1 August 2016

All gTLDs, excluding .COM, .NET and .JOBS, are required to display a Registration Data Directory Services (RDDS) output compliant with this Consensus Policy, with the exception of Registrar Registration Expiration Date and Reseller information.

  • Phase 2 - Effective Date: [Dependent on completion of IETF work, but effective 6 months after such publication]

All gTLDs, excluding .COM, .NET and .JOBS, are required to display a Registration Data Directory Services (RDDS) output fully compliant with this Consensus Policy.

  • Phase 3 - Effective Date: [To be determined]

All gTLDs, including .COM, .NET and .JOBS, are required to provide a thick Registration Data Directory Services (RDDS) fully compliant with this Consensus Policy.

The PDP Report explicitly stated, and the Implementation Plan acknowledged that the implementation of one part of the recommendation should not unnecessarily delay other parts, and the example given was that conversion to a Thick Whois for those registries that do not currently use it should not delay consistent labeling and display of data.

The ALAC would like to register its extreme dismay and dissatisfaction with the current state of this project. Specifically:

  1. The prime rational for the PDP and prime recommendation of the PDP was the move to a Thick Whois (now RDDS);
  2. The Implementation Review Team acknowledges that this, now identified as “Phase 3”, has an independent timeline from the other phases.
  3. The current proposal includes no plan and no target date for this prime requirement, but rather has focused on ancillary PDP recommendations.

Four years and four months after the issue was first addressed by the GNSO, and nearly two years after Board approval, we still have no progress and no projected completion date for the prime issue that the PDP focused on and recommended.

When people comment on the slow rate of policy development at ICANN, a common answer is that: ”it takes time to develop good policy”. There is no doubt some truth in that, and the same is likely true for the implementation of such policies.

However, soon after August 2016, the effective date of Phase 1 implementation and the only one with a firm target, we will be entering the SIXTH year of this work. Surely ICANN should be able to do better than that.

 

FIRST DRAFT SUBMITTED

(Submitted by Alan Greenberg on 08 January 2016)

The timeline for the “Thick Whois” PDP was:

  • The GNSO requested the Issue Report in September 2011;
  • The PDP was initiated by the GNSO in March 2012;
  • The Final Report was issued in October 2013;
  • The Board approved the PDP Recommendations in February 2014.

Although the PDP Charter allowed and in fact required consideration of a number of issues, the main question being asked was whether all gTLD registries should be required thick Whois services (now Registration Data Directory Services - RDDS). The prime recommendation of the PDP that “The provision of thick Whois services, with a consistent labelling and display as per the model outlined in specification 3 of the 2013 RAA1, should become a requirement for all gTLD registries, both existing and future.”

The Implementation Plan published on 25 November 2015 and the subject of this Public Comment outlines a three phase process to implement the PDP recommendations, “each with a specific scope and a dedicated timeline”. These are:

  • Phase 1 - Effective Date: 1 August 2016

All gTLDs, excluding .COM, .NET and .JOBS, are required to display a Registration Data Directory Services (RDDS) output compliant with this Consensus Policy, with the exception of Registrar Registration Expiration Date and Reseller information.

  • Phase 2 - Effective Date: [Dependent on completion of IETF work, but effective 6 months after such publication]

All gTLDs, excluding .COM, .NET and .JOBS, are required to display a Registration Data Directory Services (RDDS) output fully compliant with this Consensus Policy.

  • Phase 3 - Effective Date: [To be determined]

All gTLDs, including .COM, .NET and .JOBS, are required to provide a thick Registration Data Directory Services (RDDS) fully compliant with this Consensus Policy.

The PDP Report explicitly stated, and the Implementation Plan acknowledged that the implementation of one part of the recommendation should not unnecessarily delay other parts, and the example given was that conversion to a Thick Whois for those registries what do not currently use it should not delay consistent labelling and display of data.

The ALAC would like to register its extreme dismay and dissatisfaction with the current state of this project. Specifically:

  1. The prime rational for the PDP and prime recommendation of the PDP was the move to a Thick Whois (now RDDS);
  2. The Implementation Review Team acknowledges that this, now identified as “Phase 3”, has an independent timeline from the other phases.
  3. The current proposal includes no plan and no target date for this prime requirement, but rather has focussed on ancillary PDP recommendations.

Four years and four months after the issue was first addressed by the GNSO, and nearly two years after Board approval, we still have no progress and no projected completion date for the prime issue that the PDP focused on and recommended.

When people comment on the slow rate of policy development at ICANN, a common answer is that: ”it takes time to develop good policy”. There is no doubt some truth in that, and the same is likely true for the implementation of such policies.

However, soon after August 2016, the effective date of Phase 1 implementation and the only one with a firm target, we will be entering the SIXTH year of this work. Surely ICANN should be able to do better than that.

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