BC Comments on Latest Version of Strategic Plan

["Mike Rodenbaugh" <mike@xxxxxxxxxxxxxx>]

The Business Constituency appreciates the opportunity to comment on ICANN's
Strategic Plan.  We are in general agreement with most of the document and
its proposed timelines, although we find the document overly vague in many
respects and believe the goals ought to be more detailed.  We have not
commented on all of the Priorities as stated, and we do have other issues of
interest and concern, but these consensus comments are offered in hopes they
will be strongly considered by the ICANN Board and Staff in finalizing the
Strategic Plan.  

 

There is strong support in our membership for making DNS security and
stability the top priority in the Plan, as it is in the overall mission of
ICANN.  In particular, we recommend that Priority 2 -- Enhance security,
stability and reliliency of the Internet's Unique Indicators -- become
priority 1.  We strongly agree with this Priority as generally stated.
However the proposed implementation seems to assume that recommended "best
practices" for contracting parties are the appropriate solution to satisfy
this Priority.  We believe that contract requirements and enforcement,
rather than recommendations, may be needed to address ongoing malicious
abuse of the DNS, and in effort to prevent those exploits from spreading
exponentially throughout hundreds of new TLDs.  

 

It is of concern that ICANN is proposing the introduction of new gTLDs and
IDNs as the first priority to the organization.  There are considerable
unresolved concerns about how to undertake the further introduction of ASCII
names and how to move forward with non ASCII [IDN] strings. The BC notes
that ICANN must ensure that any further introduction of new TLDs into the
existing DNS environment must be done in a responsible, and sustainable
manner.  Today's online environment is fraught with abuse; and this is of
concern to all users, as well as governments.  In its proposed Strategic
Plan, ICANN seems to assume that it has minimal responsibility to develop
binding policy with respect to DNS abuse.  Yet it is eager to release
hundreds of new TLDs, including many IDN TLDs, which will certainly make the
internet threatscape much more treacherous for domain registrants and
internet users.  We believe ICANN should be emphasizing security
enhancements first, over and above the introduction of newTLDs.

 

ICANN has vaguely claimed that there is increased benefit to the global
community from the proposed adoption of new TLDs.  Yet this premise has
never been factually demonstrated by ICANN.  Moreover, ICANN has not
addressed the massive expense to the global business community from
defensive registrations, cybersquatting and phishing - much of which is
attributable to domain registration abuse, unmitigated by effective ICANN
policy for over ten years.  This expense is sure to increase dramatically if
hundreds of new TLDs are approved, without significant and effective policy
change to better deal with abusive registrations.  We urge ICANN to study
all of these economic impacts, report the results to the community for
comment, and to develop a plan to better enhance the security and stability
of the DNS -- before approving new TLD implementation plans.

 

We particularly agree with Priority 2.b., to "provide mechanisms that will
allow users to validate the authenticity" of DNS identifiers.  However we
are concerned with the open-ended timeline to complete this work.  We
appreciate that this Priority likely refers to DNSSEC.  However, in large
part this Priority ought to involve provision of accurate and accessible
WHOIS information, and so ICANN should continue to move rapidly to increase
both of those metrics, particularly in light of the increased use of 'proxy'
and so-called 'privacy' WHOIS services.  Shorter-term goals should be set
for accuracy and accessability thresholds at minimum levels within one or
two years, with a plan to measure and report the results on an ongoing basis
to the community.

 

We also agree with Priority 4, except that it should be emphasized over and
above the introduction of new TLDs.  Again, without a better effort at
contract compliance monitoring and enforcement within the existing gTLDs, it
makes no sense to introduce myriad new TLDs into the domain space.  We
appreciate ICANN's strides in the past two years towards better contract
compliance efforts, however this function still remains understaffed and its
work really is just beginning.  It is certainly not ready for an onslaught
of new compliance work in hundreds of new gTLDs.  We are particularly
troubled at how long it has taken the compliance team to begin studying
WHOIS accuracy and accessibility, and at how slowly that effort has moved
since inception.

 

We are concerned with Priority 9 as vaguely stated.  It is not clear what
sort of "transition to private sector management" ICANN aims to achieve
during the Plan period.  We do not support any effort by ICANN to transition
from its current status as a not-for-profit company, operating under
contract with the US Government.  Largely for the reasons stated above, we
do not believe any "transition" from this existing structure could be
appropriate during this Plan period.  

 

We hope the above comments are clear and helpful to ICANN as it moves
forward with its strategic planning, and we are happy to address any
questions about them.

 

Kind regards,

 

Mike Rodenbaugh

Officer & GNSO Councilor

Business Constituency

 

 

  _____  

From: ICANN News Alert [mailto:communications@xxxxxxxxx] 
Sent: Tuesday, December 02, 2008 2:36 PM
To: icann@xxxxxxxxxxxxxx
Subject: ICANN News Alert -- Comments Sought on Latest Version of Strategic
Plan

 

 <http://www.icann.org/> ICANN


News Alert


http://www.icann.org/en/announcements/announcement-01dec08-en.htm

  _____  


Comments Sought on Latest Version of Strategic Plan


1 December 2008

ICANN is seeking comments from the community on the latest
<http://www.icann.org/en/strategic-plan/strategic-plan-draft-2009-2012-01dec
08-en.pdf>  version of the strategic plan [PDF, 900K]. This version
incorporates comments that were received from the online forum and at the
Cairo meeting. This comment
<http://www.icann.org/en/public-comment/public-comment-200812.html#dspfc-091
2>  period is an additional short opportunity for the community to comment
before the Board considers the plan at its December meeting.

Closing date: 15 December 2008

*       Read
<http://www.icann.org/en/strategic-plan/strategic-plan-draft-2009-2012-01dec
08-en.pdf>  the latest version of the plan [PDF, 900K]
*       Send comments on the draft strategic plan: stratplan-2009@xxxxxxxxx
<mailto:%20stratplan-2009@xxxxxxxxx> 
*       View comments on the <http://forum.icann.org/lists/stratplan-2009/>
draft strategic plan

  _____  

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