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Neustar Comments on RSP Accreditation

  • To: "comments-new-gtld-draft-review-23sep15@xxxxxxxxx" <comments-new-gtld-draft-review-23sep15@xxxxxxxxx>
  • Subject: Neustar Comments on RSP Accreditation
  • From: "Song-Marshall, Judy" <judy.song@xxxxxxxxxxx>
  • Date: Mon, 7 Dec 2015 16:17:07 +0000

Neustar Inc. has been involved in the domain name industry for many years, and 
is a contracted party with ICANN as the Registry Operator for both the .biz and 
.neustar TLDs. As a result of the 2012 new gTLD process we are also responsible 
for the provision of back end registry services for 334 TLDs.
While we appreciate the detail provided in the Program Implementation Review, 
we intend to restrict our comments to Section 2.6 Technical and Operational 
Capability Evaluation of the report, and in particular, the suggestion on pg. 
79 of the report that a program to accredit registry service providers be 
We agree that there would be considerable benefit in accredit registry service 
providers. Benefits such as those outlined in the report:

·       Providing efficiencies for all parties in terms of application 
preparation and processing;

·       Allowing for the thorough review of an registry service provider’s full 
set of services provided across all TLDs;

·       Efficient management and auditing capabilities for Registry Agreements 
as the number of Registry Operators continues to increase; and

·       Streamlining processes for registry operators outside of the evaluation 
process, by allowing services to be pre-certified at the registry service 
providers level resulting in less testing.
We also note that the Preliminary Issues Report on new gTLD Subsequent 
Procedures has identified Accreditation Programs as an area for consideration, 
and in particular, whether accreditation of registry service providers would be 
Given that ICANN staff appear to be suggesting that an accreditation program 
for registry service providers would be the most efficient manner to proceed 
for a next round, and that this will also be discussed as part of the PDP WG on 
New gTLD Subsequent Procedures (anticipating that the GNSO Council will approve 
the Charter to comments the PDP in the near future), we strongly recommend that 
the process for developing an Accreditation Program for registry service 
providers commence immediately, particularly identifying the technical 
attributes or requirements of such a program. We make this recommendation based 
on a serious concern that if this work is delayed until the PDP has run its 
course, unnecessary delays will be incurred in commencing subsequent rounds.
We do not believe that commencing this work now will pre-empt any outcomes of 
the PDP and in fact could serve as an important input to the discussions. The 
questions suggested in the Preliminary Issues Report to form the basis of 
discussion are largely ‘policy’ questions and are not focussed on the technical 
attributes of an Accreditation Program.
In order to commence this work, we suggest the creation of a community working 
group comprising representatives that have the necessary skills and expertise 
to develop a strawman of the set of technical attributes required for 
accrediting registry service providers. We also believe that ICANN staff and 
evaluators involved in the technical related aspects of the new gTLD process 
would also be well-placed to contribute to this effort. Any output from this 
working group draft would be subject to public comment to ensure community 
involvement to the process.

Attachment: Neustar Comments on RSP Accreditation v1.pdf
Description: Neustar Comments on RSP Accreditation v1.pdf

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