The BC filed the comment below (also attached), regarding ICANN’s draft report on Continuous Data-Driven Analysis of Root Server System Stability (CDAR) Thanks to Denise Michel for drafting. From: Steve DelBianco <sdelbianco@netchoice.org<mailto:sdelbianco@netchoice.org>> Date: Thursday, December 22, 2016 at 8:45 AM To: "comments-cdar-draft-27oct16@icann.org<mailto:comments-cdar-draft-27oct16@icann.org>" <comments-cdar-draft-27oct16@icann.org<mailto:comments-cdar-draft-27oct16@icann.org>> Subject: Business Constituency (BC) comment on Continuous Data-Driven Analysis of Root Server System Stability Draft Report The ICANN Business Constituency (BC) submits the comment below, regarding the Draft Report on Continuous Data-Driven Analysis of Root Server System Stability (CDAR) The Business Constituency acknowledges the importance of examining the technical impact of the New gTLD Program on the root server system scalability. This is a critical path review that not only should be completed and addressed before launching the next round of new gTLDs, but related, ongoing data collection, analysis and publication should be a high priority for ICANN. The BC commends the authors for providing a clear, concise and well written draft report. The BC also commends the authors for considering and responding to the BC’s previous comments on the CDAR Study Plan that guided their work. We strongly agree with the draft report that “the absence of an observed degradation of the security and stability of the root DNS system is no reason to be less cautious about possible future impact of New gTLD Program.” The BC wholly endorse the draft report recommendations: “In particular, we recommend the New gTLD Program to continue enforcing a gradual rate of delegating new gTLDs, which is one of its current preventive root zone scaling measures. Further, we advise more continuous monitoring of the impact of new gTLD delegations. To enable monitoring in a more continuous manner, an upgrade of current data collection efforts is recommended. Finally, we recommend including continuous monitoring of the identified risk parameters.” The BC asks that ICANN’s Chair and CEO confirm that these recommendations will be fully implemented and that relevant data, analysis and monitoring reports be publicly posted. Further, the BC reiterates its recommendation that new gTLD impacts on addresses also be assessed and monitored and that relevant reports and data be made publicly available. -- This comment was drafted by Denise Michel and was approved in accord with our charter. — Steve DelBianco Vice chair for policy coordination ICANN Business Constituency