Regarding High Security Top-Level Domain (HSTLD) and Draft Program Development Snapshot

[Dave Smiley <elimsad@xxxxxxxxxxx>]

Dear Sir,Madam-

I like modeling the Security Verification process on IT industry recognized 
certifications like SysTrust/WebTrust  but would like to make sure there is at 
least one other option that would satisfy HSTLD requirements.  There seem to be 
many layers of approvals (and associated fees) in the “name of security” and, 
though well meaning, this will stifle innovation and inhibit the global 
benefits we strive for due to high costs (application, verification, annual 
audit, registry fees, etc..).  A better balance must be struck between real 
security issues and market forces, e.g., allowing potential registrants to 
decide whether to use a certain HSTLD (possibly based on audits and 
certifications it has obtained, insurance statements, imprimatur from 
government, or other reputational endorsements), but NOT mandated by ICANN.

I worry that ICANN staff may be drinking too much of its own cool-aid with 
respect to the role DNS has in the overall Internet ecosystem.  Let’s be real 
here.

A "seal" is not that important and should not end up being perceived as an 
ICANN profit center.  I believe it benefits both the public and ICANN to be 
seen as the benevolent body it has been for all these years - not as a trade 
association. 

I fear once again that ICANN and its well meaning staff may have listened too 
much to its own myopic community of followers and erring on the side of over 
regulation and not taking into account free market principles.  

Please make sure to fully consider the views from the businesses and 
entrepreneurs that will turn the HSTLD+DNSSEC combination into a "platform for 
innovation and international cooperation in cybersecurity" (from an ICANN 
presentation) so everyone can benefit,  instead of a playground for 
policy/technical/regulatory elites to run amok.

Finally please get your own house in order.  If we are to rely on the HSTLDs 
for security, the whole chain must be secured - specifically, the process by 
which HSTLD keys (and other changes) would be incorporated into the root zone.  
Presently I understand this to be a highly insecure process spread across 
multiple organizations with little rigor around security processes. I note that 
in your 2009-11-18 document entitled “A Model for High Security Zone 
Verification Program”, there is the mention of "strong multi factor 
authentication throughout the namespace".  Well, ICANN must apply the same to 
the above part of the chain otherwise the HSTLD loses its value.   There have 
been many technical proposals to solving this processing insecurity over the 
years (e.g. changes sent directly to the root maintainer in SMIME signed email 
by HSTLD operator for validation by the maintainer.  This creates a publicly 
verifiable chain of trust with no opportunity for
 changes by intermediaries).  So I assume the problem is a political one.  
However, until the same rigorous security practices expected of the HSTLD 
applicant are put in place, the security of the HSTLD means little.

Thank you for this opportunity to comment.

Regards,
Dave