The SSAC welcomes the opportunity to comment on ICANN’s Draft Applicant Guidebook (AGB) for the New gTLD Program: Next Round. Our comments focus on improving Section 6.7 on Name Collisions, with an emphasis on risks arising from collisions between DNS and alternative naming systems (e.g., blockchain-based systems), as outlined in the Name Collision Analysis Project Study 2 Report (NCAP2).

Summary of Key Recommendations:

1. Clarify TRT’s Role in Initial Assessments
   AGB §6.7.2 does not clearly state that the Technical Review Team (TRT) conducts the initial name collision risk assessment. NCAP2 indicates TRT is responsible from the outset.
   Recommendation: Explicitly assign the initial assessment to the TRT.

2. Enable Pre-Delegation Action on High-Risk Strings
   Current language suggests high-risk strings are identified only after temporary delegation. NCAP2 supports action based on existing data.
   Recommendation: Allow TRT to recommend withholding delegation if early analysis shows high risk.

3. Broaden TRT’s Assessment Scope Beyond DNS Data
   Limiting analysis to DNS logs misses collisions from alternative namespaces that resolve via DNS (e.g., users accustomed to .wallet from blockchain).
   Recommendation: Permit use of OSINT, qualitative assessments, and external data sources per NCAP2.

4. Allow TRT Flexibility to Evolve Assessment Methods
   AGB cites four NCAP2 methods (NI, CI, VI, VIN), but doesn’t state whether TRT may adopt new techniques.
   Recommendation: Affirm TRT’s discretion to evolve methods to address future risks.

These updates will better align the AGB with NCAP2 and ICANN Board guidance, while improving transparency, security, and technical rigor in handling name collisions.

The SSAC appreciates the efforts of the ICANN org and Subsequent Procedures IRT, and we are available for further discussion.

Link: https://itp.cdn.icann.org/en/files/security-and-stability-advisory-committee-ssac-reports/sac-130-22-07-2025-en.pdf.