ISP and Connectivity Provider (ISPCP) constituency comments on ICANN's proposal to mitigate name collision risks

["Mike O'Connor" <mike@xxxxxxxxxx>]

Dear ICANN,

The Internet Service Providers and Connectivity Providers constituency (ISPCP) 
respectfully submits the following comments on ICANN's August 5 Proposal to 
Mitigate Name Collision Risks.

We are available to respond to any questions or comments.

Best regards,

Mike O'Connor -- ISPCP Rapporteur 

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ISPCP Comment

Whereas: the potential for name collision may be substantial

Whereas: the potential for name collision often arises from well-established 
policies and practices in private network environments

Whereas: the risk associated with delegating a new TLD label arises from the 
potentially harmful consequences of name collision, not the collision itself

Whereas: name collision in general may threaten the assumption that an 
identifier containing a DNS domain name will always point to the same thing

Whereas: the opportunity for X.509 public key certificates to be erroneously 
accepted as valid is an especially troubling consequence of name collision

Whereas: designation of any applied-for string as “high risk” or “low risk” 
with respect to delegation as a new gTLD depends on both policy and analysis -- 
activities which have not yet been completed

Whereas: the analysis to evaluate the nature and impact of name-collision risk 
has not been completed

Whereas: corporations, ISPs and connectivity providers may bear the brunt of 
the security and customer-experience issues resulting from adverse (as yet 
un-analyzed) impacts from name collision

Whereas: those same corporations are in large part not active participants in 
the ICANN community and are only just becoming aware of these issues

Whereas: these issues, due to their security and customer-experience aspects, 
fall outside the remit of people who normally participate in the ICANN process, 
requiring extensive wide-ranging briefings even in corporations that do 
participate actively in the ICANN process

Therefore, the ISPCP requests the following.

-- that ICANN complete further study of name-collision issues to understand 
their nature and impact, following the recommendations made in the InterIsle 
report
 
-- That the initial public comment period be placed on hold until such a study 
is completed, or if that is deemed infeasible, at least extended for 60 days to 
allow a more detailed assessment of the important issues raised