January 2020 - comments-atrt3-draft-report-16dec19@icann.org

[Comments-atrt3-draft-report-16dec19] Public Comment on the third Accountability and Transparency Review Team (ATRT3) Draft Report
by Wendy Profit Jan. 31, 2020

Jan. 31, 2020

Sent on behalf of the ICANN Board Dear members of the ATRT3, Please, find attached the ICANN Board’s Public Comment Submission on the third Accountability and Transparency Review Team (ATRT3) Draft Report. Kind regards, Wendy Profit ICANN Board Operations Senior Manager 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094

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[Comments-atrt3-draft-report-16dec19] SSR
by Weissinger, Laurin Jan. 31, 2020

Jan. 31, 2020

The aim (option 2) to reduce the SSR review to short workshops is concerning. While the OCTO team is doing a lot of excellent work (e.g. outreach, engagement, stakeholder support, etc.) and SSAC and RSSAC contribute important advice, there are systemic security issues within the DNS and the ICANN ecosystem that need to be addressed. For example, ICANN contracts do not properly address systemic abuse (https://www.icann.org/en/system/files/correspondence/hedlund-to-vayra-04apr…, p.2). Issues with ICANN’s approach to security and anti-abuse are also documented by multiple review teams. It is obvious that improving on security is paramount and requires proper oversight and/or audit mechanisms. Many approaches to addressing security vulnerabilities and lacking anti-abuse provisions do exist. Likewise, many options exist for overseeing the process — but the key to all of them is to have actual oversight, transparency, and consequences / actions to address SSR concerns. Continuous assessment and audits by independent third parties, reviewed by the community in intervals or partly “staffed” by community volunteers, could be an approach as well as shorter but more frequent reviews on SSR, e.g. twice per year. In the latter case, having overlapping terms (at least 1 year overlap, better 1.5/2) to ensure knowledge transfer would be useful. Whatever is finally recommended should be fleshed out more and explain how the future process could uphold a level of oversight and transparency appropriate for such an important concern. Laurin Weissinger, in personal capacity (For the record: Yale University, and SSR2 co-vice chair)

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[Comments-atrt3-draft-report-16dec19] Comment on ATRT3 report
by Chokri Ben Romdhane Jan. 31, 2020

Jan. 31, 2020

Dear friends please find my comments about ATRT3 recommandations , -Issue:Public Input The public comment process may include a mechanism that give the opportunity to commentaires to give their opinions about the staff report on the Public Comment proceeding and to claim any omission. -Issue Policy Development Process : The PDP working groups should develop their policies independently of any technical issues, and any technical or jurisdiction study should only support and not influence policies and transform them in technical solutions rather then a policies applying for differents technical issues. All the parties including the board should avoid such technical or juridiction study that will limit the scope of those working groups. Freindly Chokri Ben Romdhane

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[Comments-atrt3-draft-report-16dec19] RySG Comment on ATRT3 Draft Report
by Demetriou, Samantha Jan. 31, 2020

Jan. 31, 2020

Hello, On behalf of the gTLD Registries Stakeholder Group (RySG), please find attached our comments on the Third Accountability and Transparency Review Team (ATRT3) Draft Report. In the interest of time, we did not conduct a vote on these comments. We did discuss them on our mailing list and during a biweekly conference call, and no member opposed their submission. Please feel free to contact me with any questions or concerns. Best, Samantha Demetriou RySG Vice Chair, Policy

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[Comments-atrt3-draft-report-16dec19] Pending Ratification: ALAC Statement on Third Accountability and Transparency Review Team (ATRT3) Draft Report
by ICANN At-Large Staff Jan. 31, 2020

Jan. 31, 2020

Dear All, Please find attached the ALAC statement regarding Third Accountability and Transparency Review Team (ATRT3) Draft Report<https://community.icann.org/x/_gRxBw>. In the interest of time, the ALAC Chair requested that the statement be transmitted to the ICANN public comment process with a note that the statement is pending ALAC ratification. Kind Regards, ICANN Policy Staff in support of the At-Large Community Website: atlarge.icann.org<https://atlarge.icann.org/> Facebook: facebook.com/icann<https://www.facebook.com/icannatlarge>atlarge<https://www.facebook.com/icannatlarge> Twitter: @<https://twitter.com/ICANNAtLarge>ICANNAtLarge<https://twitter.com/ICANNAtLarge>

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[Comments-atrt3-draft-report-16dec19] Business Constituency (BC) comment on 3rd Accountability and Transparency Review Team (ATRT3) Draft Report
by Steve DelBianco Jan. 31, 2020

Jan. 31, 2020

Attached is the comment of ICANN’s Business Constituency (BC) regarding the third Accountability and Transparency Review Team (ATRT3) Draft Report. This comment was drafted by Steve DelBianco, Barbara Wanner, Tola Sogbesan, and Denise Michel. It was approved in accord with our Charter. -- Steve DelBianco Vice Chair for Policy Coordination ICANN Business Constituency (BC)

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[Comments-atrt3-draft-report-16dec19] RrSG response to ATRT3 Draft Report
by Zoe Bonython Jan. 31, 2020

Jan. 31, 2020

Hello, On behalf of the Registrar Stakeholder Group (RrSG), I would like to submit the attached response to the ATRT3 Draft Report. Kind regards, Zoe Bonython RrSG Secretariat

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[Comments-atrt3-draft-report-16dec19] SSAC2020-05: SSAC Public Comment on Third Accountability and Transparency Review Team (ATRT3) Draft Report
by Andrew McConachie Jan. 30, 2020

Jan. 30, 2020

On behalf of the Security and Stability Advisory Committee (SSAC) please find SSAC2020-05: SSAC Public Comment on Third Accountability and Transparency Review Team (ATRT3) Draft Report attached. Sincerely, Andrew McConachie ICANN Policy Support for the SSAC

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[Comments-atrt3-draft-report-16dec19] GNSO IPC Comments re Third Accountability and Transparency Review Team (ATRT3) Draft Report
by Brian Scarpelli Jan. 30, 2020

Jan. 30, 2020

On behalf of the GNSO Intellectual Property Constituency, please find attached comments of the IPC on the Third Accountability and Transparency Review Team (ATRT3) Draft Report. Brian Scarpelli Senior Global Policy Counsel +1 517-507-1446<mailto:+1%20517-507-1446> | bscarpelli(a)actonline.org<mailto:bscarpelli@actonline.org> ACT | The App Association 1401 K St NW (Ste 501) Washington, DC 20005

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[Comments-atrt3-draft-report-16dec19] Regarding sections 10.5
by Heather Flanagan Jan. 29, 2020

Jan. 29, 2020

Hello review team members, The reviews I’ve read through or observed to date appear to come down to two basic characteristics and requirements: 1 - They need to hold ICANN accountable to the world that ICANN is doing what it says it’s going to do in its policies and procedures. 2 - They need to be handled in a timely enough fashion that ICANN has time to respond to the review and change their processes and procedures as necessary. The current review team model is indeed dysfunctional, with too many reviews running at the same time, and too many recommendations for ICANN to be able to respond to effectively, and it does not appear that the current review process is meeting either of those basic requirements. Rather than require a review team to try and do all its work in a 5 day workshop, which seems unreasonable and almost designed to result in a very shallow review, I personally would recommend that ICANN treat this as a more typical audit process and hire a firm that does audits for a living to evaluate if ICANN is following its own processes and procedures, and to make recommendations where those processes/procedures are insufficient or otherwise not being met. The final report from the audit company can be made available for public comment, thus keeping that public accountability open. It may be that an audit isn’t a correct model in all cases, but it certainly will fill some (e.g., SSR and WHOIS/RDS) but the idea has the potential to cut down on the number of review teams running concurrently, and given the contractual arrangement with an audit firm, you can set a more reasonable time limit (e.g., 6 months per review). I hope this suggestion is useful, and I wish you the best with wrapping up the ATRT3 process. Heather Flanagan

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