ISPCP Public Comments to JAS Report

[Christian Dawson <dawson@xxxxxxxxxxx>]

What follows is comments from the Internet Service Providers & Connectivity 
Providers (ISPCP) constituency:

1) Thanks to ICANN and JAS for their hard work.

2) If Controlled Interruption moves forward in the manner suggested by the JAS 
report, every possible second level domain would be delegated by wildcard (or 
every domain on the block list for those already delegated) to 127.0.53.53. 
There should be an exception process for delegations where the nature, and 
source of the requests to the root zone have already been narrowly identified 
and where the registry requests or accepts to not delegate all names.  
Otherwise, the Controlled Interruption may create risks without any additional 
value, and network operators will be warned of collisions that are likely to 
never come, causing untold amounts of work from sysadmins for no tangible 
benefit.

3) If Controlled Interruption moves forward in the manner suggested by the JAS 
report, a feedback loop needs to be developed to determine the ongoing efficacy 
of the program. By gathering and processing data about response to the 
Controlled Interruption process, we can get smarter and more efficient about 
minimizing the risk of collisions in the future.

4) One thing we like about Controlled Interruption via 127.0.53.53 IF it proves 
effective is that it makes the problem easily identifiable, so that solutions 
can be found via search engine by sysadmins. Whatever methodology moves forward 
must have the network sysadmin in mind, and must give the sysadmin who is 
likely unfamiliar with new gTLDs a pathway to identify and solve issues as 
quickly and easily as possible.

5) We will never have sufficient data to know for certain what will break 
during delegation. We ought to focus as much of our attention as possible on 
documentation and outreach. The report states the outreach done to date, and 
that's a good start. These efforts need to continue to grow over time and 
cannot end when the full report is issued.