[bc-gnso] CORRECTION: Business Constituency comment on FY 2012 SSR Framework

[Steve DelBianco <sdelbianco@xxxxxxxxxxxxx>]

I meant to say, thanks to ADAM PALMER and Mikey O'Connor for their work on the 
SSR review team comments earlier this year.


On 6/7/11 9:02 PM, "Steve DelBianco" 
<sdelbianco@xxxxxxxxxxxxx<mailto:sdelbianco@xxxxxxxxxxxxx>> wrote:

Below (and attached) are comments the BC submitted today for ICANN's proposed 
2012 framework for Security, Stability, and Resiliency (SSR). 
http://www.icann.org/en/public-comment/#ssr-fy12

As discussed on last week's BC call and my follow-up email, we re-submitted the 
BC's 4-Apr response to SSR review team issues.    In the body of our comment 
submission (below), we adapted the introductory paragraphs from that 
submission, with minor edits by Marilyn Cade and I.

Thanks again to Berry Cobb and Mikey O'Connor for their work on the SSR review 
team comments earlier this year.

--Steve


----

The Business Constituency (BC) is fully committed and concerned with
maintaining the security, stability, and resiliency of the DNS.

In the designated comment period for this proposed SSR Framework, the BC
was otherwise engaged and therefore unable to do a detailed analysis and
response.

However, the BC would like to re-iterate relevant concerns that we
submitted on 6-Apr-2011, for the SSR Affirmation Review Team Set of Issues
(see http://forum.icann.org/lists/ssr-rt-issues/msg00004.html):


Business users rely on a stable and secure Internet and e-commerce
experience, one that serves their users and customers on a global basis.
Although ICANN is an independent non-profit corporation, its decisions
directly impact a larger eco system that is extensively designed and
financed by BC members, including communication service providers, ISPs,
cable providers; application and content service providers, as well as
domain portfolio managers, and the online commerce community.

The BC supports ICANN's continuing effort to improve SSR and believes that
attention should be focused on four areas of current concern:

1. Adequacy of measures to prevent DNS Abuse
2. Lack of Collaboration with Enterprise Community
3. Oversight and resources to ensure compliance obligations are enforced
4. Strategic planning for SSR should include the business user community

ICANN's Bylaws require it 'to ensure the stable and secure operation' of
the DNS. Therefore, ICANN must view participation in coordinated industry
efforts to combat malicious DNS activity as absolutely essential to that
mission.

Fraudulent WHOIS, manipulation of DNS records, and ICANN's failure to
adequately enforce obligations of contracted parties continues to provide
fertile ground for abuses that erode trust in e-commerce.

The BC is encouraging ICANN to recognize that its mission requires timely
enforcement of contracted party compliance obligations and collaborative
support for enterprise efforts to identify and address attacks that abuse
DNS technologies.

The BC has strong concerns that ICANN's current SSR plans fail to
adequately emphasize cooperation with the business community to protect
e-commerce. The SSR plan also lacks a detailed description of how ICANN
will focus on creating an effective compliance program.

The lack of an emphasis on improving compliance leaves doubt that any plan
will be effective. ICANN
continues to endorse a narrow view of its compliance obligations. This
provides little assurance that ICANN will take the necessary action to
enforce security standards. The current SSR proposal appears heavy with
good intentions, but provides few substantive details or assurances of
action that would persuade the BC that it would be effective.

The introduction of new gTLDs -- including IDNs with their special
characteristics -- makes this a critically important moment for ICANN to
develop a robust SSR plan that will protect e-commerce and promote
security. This SSR Review is an excellent way to describe shortfalls in
current plans and compliance, and to recommend improvements that can be
implemented before doubling or tripling the number of TLDs in use.

The planned SSR Summit lacks input from the business user community, and
the BC welcomes the opportunity to identify the relevance, scope and
purpose of the proposed summit.

The full text of our SSR submission to the Affirmation Review team are
attached.

We look forward to receiving details underlying the SSR Framework and to
making further comments at the Singapore meeting.

--
Steve DelBianco
Vice chair for policy coordination
ICANN Business Constituency
http://Www.bizconst.org