SSAC has published SSAC2025-01: SSAC Public Comment for Fourth Proceeding for Proposed Language for Draft Sections of Next Round Applicant Guidebook
Hi colleagues, the SSAC has published SSAC2025-01. ### SSAC has published SSAC2025-01: SSAC Public Comment for Fourth Proceeding for Proposed Language for Draft Sections of Next Round Applicant Guidebook: The SSAC has reviewed the draft language of Topic 29 in the Applicant Guidebook (AGB) and wishes to highlight several key concerns and recommendations to ensure the effectiveness of the Name Collision Risk Assessment Framework and its alignment with the NCAP2 Final Report and SAC124 guidance: 1. Clarity on DNS Assessment Methods · SSAC seeks explicit confirmation on which of the DNS-related assessment methods from NCAP2 (No Interruption, Controlled Interruption, Visible · Interruption) will be implemented during temporary delegation. · There is a concern that "Visible Interruption and Notification" has been omitted, despite its unique value in supporting root cause analysis for name collisions. · SSAC requests that any excluded methods be clearly justified, and encourages ICANN org to consider the need for sufficient data collection in all cases. · The SSAC underscores that the Technical Review Team (TRT), as recommended in NCAP2, should be involved in determining the appropriate assessment methods. 2. Support for Effective Mitigation and Remediation · SSAC emphasizes that DNS query data alone is insufficient to fully diagnose name collisions or develop robust mitigation plans. · The "Visible Interruption and Notification" method is critical because it collects application-layer data, offering qualitative insights that DNS-only methods cannot provide. · SSAC questions its exclusion from the current draft and reiterates the importance of combining quantitative and qualitative data to properly assess and mitigate risks. · The SSAC again refers to SAC124 Recommendation 2, urging ICANN to adopt solutions that enable comprehensive data collection and analysis. 3. Role and Implementation of the Technical Review Team (TRT) · SSAC supports the creation of a dedicated TRT as outlined in NCAP2 Recommendation 7 and requests more detail on how it will be structured, what responsibilities it will have, and how it will interact with applicants. · Currently, the draft only refers to the TRT in limited ways (e.g., in mitigation plan evaluation), and the SSAC recommends strengthening this · by: o Replacing “may advise” with “should advise” when referring to TRT input on mitigation plans. o Ensuring TRT participation in the Initial Assessment phase and requiring their availability to explain assessment findings to applicants. · These enhancements would promote transparency, collaboration, and a more technically informed approach to name collision risk management. Conclusion SSAC urges ICANN to revise the draft Topic 29 to: · Clearly outline the chosen DNS assessment methods and rationale for exclusions; · Reinstate and justify the role of “Visible Interruption and Notification” where applicable; · Define the scope, authority, and involvement of the Technical Review Team throughout the assessment and remediation process. These steps are essential to uphold the integrity of the Name Collision Risk Framework and ensure the stability and security of the DNS. Link to the report: https://itp.cdn.icann.org/en/files/security-and-stability-advisory-committee... Have a nice day! Best, Matthias ______________________________ Ing. Mag. Matthias M. Hudobnik FIP • CIPP/E • CIPT • DPO • CIS LA matthias@hudobnik.at http://www.hudobnik.at @mhudobnik
Ne prepared to discuss these recs on Wednesday. We're big fans of collision risk management Get Outlook for Android<https://aka.ms/AAb9ysg> ________________________________ From: Matthias M. Hudobnik via At-Large <at-large@icann.org> Sent: Friday, April 4, 2025 10:38:11 AM To: 'At-Large Worldwide' <at-large@atlarge-lists.icann.org> Subject: [At-Large] SSAC has published SSAC2025-01: SSAC Public Comment for Fourth Proceeding for Proposed Language for Draft Sections of Next Round Applicant Guidebook Hi colleagues, the SSAC has published SSAC2025-01. ### SSAC has published SSAC2025-01: SSAC Public Comment for Fourth Proceeding for Proposed Language for Draft Sections of Next Round Applicant Guidebook: The SSAC has reviewed the draft language of Topic 29 in the Applicant Guidebook (AGB) and wishes to highlight several key concerns and recommendations to ensure the effectiveness of the Name Collision Risk Assessment Framework and its alignment with the NCAP2 Final Report and SAC124 guidance: 1. Clarity on DNS Assessment Methods · SSAC seeks explicit confirmation on which of the DNS-related assessment methods from NCAP2 (No Interruption, Controlled Interruption, Visible · Interruption) will be implemented during temporary delegation. · There is a concern that "Visible Interruption and Notification" has been omitted, despite its unique value in supporting root cause analysis for name collisions. · SSAC requests that any excluded methods be clearly justified, and encourages ICANN org to consider the need for sufficient data collection in all cases. · The SSAC underscores that the Technical Review Team (TRT), as recommended in NCAP2, should be involved in determining the appropriate assessment methods. 2. Support for Effective Mitigation and Remediation · SSAC emphasizes that DNS query data alone is insufficient to fully diagnose name collisions or develop robust mitigation plans. · The "Visible Interruption and Notification" method is critical because it collects application-layer data, offering qualitative insights that DNS-only methods cannot provide. · SSAC questions its exclusion from the current draft and reiterates the importance of combining quantitative and qualitative data to properly assess and mitigate risks. · The SSAC again refers to SAC124 Recommendation 2, urging ICANN to adopt solutions that enable comprehensive data collection and analysis. 3. Role and Implementation of the Technical Review Team (TRT) · SSAC supports the creation of a dedicated TRT as outlined in NCAP2 Recommendation 7 and requests more detail on how it will be structured, what responsibilities it will have, and how it will interact with applicants. · Currently, the draft only refers to the TRT in limited ways (e.g., in mitigation plan evaluation), and the SSAC recommends strengthening this · by: o Replacing “may advise” with “should advise” when referring to TRT input on mitigation plans. o Ensuring TRT participation in the Initial Assessment phase and requiring their availability to explain assessment findings to applicants. · These enhancements would promote transparency, collaboration, and a more technically informed approach to name collision risk management. Conclusion SSAC urges ICANN to revise the draft Topic 29 to: · Clearly outline the chosen DNS assessment methods and rationale for exclusions; · Reinstate and justify the role of “Visible Interruption and Notification” where applicable; · Define the scope, authority, and involvement of the Technical Review Team throughout the assessment and remediation process. These steps are essential to uphold the integrity of the Name Collision Risk Framework and ensure the stability and security of the DNS. Link to the report: https://itp.cdn.icann.org/en/files/security-and-stability-advisory-committee... Have a nice day! Best, Matthias ______________________________ Ing. Mag. Matthias M. Hudobnik FIP • CIPP/E • CIPT • DPO • CIS LA matthias@hudobnik.at http://www.hudobnik.at @mhudobnik
Thanks, Matthias. I also saw this off the relevant public comment proceeding wiki page and I plan to follow up with Jim Galvin to make sure the comments get addressed at an upcoming SubPro IRT meeting. Jim is the SSAC's SME and point of contact for the said IRT in respect of name collision. Justine On Sat, 5 Apr 2025 at 03:49, Jonathan Zuck via At-Large <at-large@icann.org> wrote:
Ne prepared to discuss these recs on Wednesday. We're big fans of collision risk management
Get Outlook for Android <https://aka.ms/AAb9ysg> ------------------------------ *From:* Matthias M. Hudobnik via At-Large <at-large@icann.org> *Sent:* Friday, April 4, 2025 10:38:11 AM *To:* 'At-Large Worldwide' <at-large@atlarge-lists.icann.org> *Subject:* [At-Large] SSAC has published SSAC2025-01: SSAC Public Comment for Fourth Proceeding for Proposed Language for Draft Sections of Next Round Applicant Guidebook
Hi colleagues, the SSAC has published SSAC2025-01.
*### **SSAC has published SSAC2025-01: SSAC Public Comment for Fourth Proceeding for Proposed Language for Draft Sections of Next Round Applicant Guidebook:*
The SSAC has reviewed the draft language of Topic 29 in the Applicant Guidebook (AGB) and wishes to highlight several key concerns and recommendations to ensure the effectiveness of the Name Collision Risk Assessment Framework and its alignment with the NCAP2 Final Report and SAC124 guidance:
*1. Clarity on DNS Assessment Methods*
· SSAC seeks explicit confirmation on which of the DNS-related assessment methods from NCAP2 (No Interruption, Controlled Interruption, Visible
· Interruption) will be implemented during temporary delegation.
· There is a concern that "Visible Interruption and Notification" has been omitted, despite its unique value in supporting root cause analysis for name collisions.
· SSAC requests that any excluded methods be clearly justified, and encourages ICANN org to consider the need for sufficient data collection in all cases.
· The SSAC underscores that the Technical Review Team (TRT), as recommended in NCAP2, should be involved in determining the appropriate assessment methods.
*2. Support for Effective Mitigation and Remediation *
· SSAC emphasizes that* DNS query data alone is insufficient *to fully diagnose name collisions or develop robust mitigation plans.
· The "Visible Interruption and Notification" method is critical because it collects* application-layer data*, offering qualitative insights that DNS-only methods cannot provide.
· SSAC questions its exclusion from the current draft and reiterates the importance of combining *quantitative and qualitative data *to properly assess and mitigate risks.
· The SSAC again refers to SAC124 Recommendation 2, urging ICANN to adopt solutions that enable* comprehensive data collection and analysis.*
*3. Role and Implementation of the Technical Review Team (TRT)*
· SSAC supports the creation of a dedicated TRT as outlined in NCAP2 Recommendation 7 and requests more detail on how it will be structured, what responsibilities it will have, and how it will interact with applicants.
· Currently, the draft only refers to the TRT in limited ways (e.g., in mitigation plan evaluation), and the SSAC recommends strengthening this
· by:
o Replacing “may advise” with *“should advise”* when referring to TRT input on mitigation plans.
o Ensuring TRT participation in the *Initial Assessment* phase and requiring their availability to *explain assessment findings* to applicants.
· These enhancements would promote transparency, collaboration, and a more technically informed approach to name collision risk management.
*Conclusion*
SSAC urges ICANN to revise the draft Topic 29 to:
· Clearly outline the chosen DNS assessment methods and rationale for exclusions;
· Reinstate and justify the role of “Visible Interruption and Notification” where applicable;
· Define the scope, authority, and involvement of the Technical Review Team throughout the assessment and remediation process.
These steps are essential to uphold the integrity of the Name Collision Risk Framework and ensure the stability and security of the DNS.
Link to the report: https://itp.cdn.icann.org/en/files/security-and-stability-advisory-committee...
Have a nice day!
Best,
Matthias
______________________________
Ing. Mag. Matthias M. Hudobnik
FIP • CIPP/E • CIPT • DPO • CIS LA
matthias@hudobnik.at
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participants (3)
-
Jonathan Zuck -
Justine Chew -
Matthias M. Hudobnik