Below (and attached) are comments the BC submitted today for ICANN's proposed 2012 framework for Security, Stability, and Resiliency (SSR). http://www.icann.org/en/public-comment/#ssr-fy12 As discussed on last week's BC call and my follow-up email, we re-submitted the BC's 4-Apr response to SSR review team issues. In the body of our comment submission (below), we adapted the introductory paragraphs from that submission, with minor edits by Marilyn Cade and I. Thanks again to Berry Cobb and Mikey O'Connor for their work on the SSR review team comments earlier this year. --Steve ---- The Business Constituency (BC) is fully committed and concerned with maintaining the security, stability, and resiliency of the DNS. In the designated comment period for this proposed SSR Framework, the BC was otherwise engaged and therefore unable to do a detailed analysis and response. However, the BC would like to re-iterate relevant concerns that we submitted on 6-Apr-2011, for the SSR Affirmation Review Team Set of Issues (see http://forum.icann.org/lists/ssr-rt-issues/msg00004.html): Business users rely on a stable and secure Internet and e-commerce experience, one that serves their users and customers on a global basis. Although ICANN is an independent non-profit corporation, its decisions directly impact a larger eco system that is extensively designed and financed by BC members, including communication service providers, ISPs, cable providers; application and content service providers, as well as domain portfolio managers, and the online commerce community. The BC supports ICANN's continuing effort to improve SSR and believes that attention should be focused on four areas of current concern: 1. Adequacy of measures to prevent DNS Abuse 2. Lack of Collaboration with Enterprise Community 3. Oversight and resources to ensure compliance obligations are enforced 4. Strategic planning for SSR should include the business user community ICANN's Bylaws require it 'to ensure the stable and secure operation' of the DNS. Therefore, ICANN must view participation in coordinated industry efforts to combat malicious DNS activity as absolutely essential to that mission. Fraudulent WHOIS, manipulation of DNS records, and ICANN's failure to adequately enforce obligations of contracted parties continues to provide fertile ground for abuses that erode trust in e-commerce. The BC is encouraging ICANN to recognize that its mission requires timely enforcement of contracted party compliance obligations and collaborative support for enterprise efforts to identify and address attacks that abuse DNS technologies. The BC has strong concerns that ICANN's current SSR plans fail to adequately emphasize cooperation with the business community to protect e-commerce. The SSR plan also lacks a detailed description of how ICANN will focus on creating an effective compliance program. The lack of an emphasis on improving compliance leaves doubt that any plan will be effective. ICANN continues to endorse a narrow view of its compliance obligations. This provides little assurance that ICANN will take the necessary action to enforce security standards. The current SSR proposal appears heavy with good intentions, but provides few substantive details or assurances of action that would persuade the BC that it would be effective. The introduction of new gTLDs -- including IDNs with their special characteristics -- makes this a critically important moment for ICANN to develop a robust SSR plan that will protect e-commerce and promote security. This SSR Review is an excellent way to describe shortfalls in current plans and compliance, and to recommend improvements that can be implemented before doubling or tripling the number of TLDs in use. The planned SSR Summit lacks input from the business user community, and the BC welcomes the opportunity to identify the relevance, scope and purpose of the proposed summit. The full text of our SSR submission to the Affirmation Review team are attached. We look forward to receiving details underlying the SSR Framework and to making further comments at the Singapore meeting. -- Steve DelBianco Vice chair for policy coordination ICANN Business Constituency http://Www.bizconst.org