Dear Mikey:
As Stephanie notes, the EWG plans to issue its final report at (before?) ICANN London in June. At that point the community will find out exactly what the EWG proposes, with hopefully a full explanation of why. Then the GNSO, the Board, and the community will need to decide whether the EWG’s proposals are good ones or not. I assume that there will be a formal public comment period for the EWG’s final report; the GNSO should confirm that in Singapore. I’m an expert on WHOIS, and I found the EWG’s interim report to be so impenetrable that it resisted interim comment (sorry, Stephanie!).
When the EWG was formed, ICANN said “The working group's results will feed into the GNSO's bottom-up, policy development process where all community interests will be encouraged to participate in the decision-making.” If I have any personal advice for the GNSO, it is not to accept any fait accomplis. The EWG is to propose policies, and I suggest that those proposals shouldn’t be allowed to take on a life of their own and be considered done deals or the only alternatives. Part of the process should be a careful exploration of the implications and impacts of the proposed policies, and what alternative proposals may be proposed. The EWG is doing some due diligence, but it has to finish its work soon and the GNSO will need to assume responsibility for further diligence and studies.
Where are things with establishing a registration data policy? That is an interesting question. The EWG’s initial report did not do a good job IMHO at proposing policies. Here’s how SSAC061 put the problem; I think it is worth reiterating:
“The EWG, in parallel to proposing a new model for the purpose of registration data, discussed several ‘system designs’ for access to the data and proposed one model, calling for a centralized registration data repository. That approach poses a quandary: policies are expressions of goals and should articulate the problems the community designed them to solve. Until proposed registration data policies and their justifications are stated clearly, it is not possible to comment definitively on their security and stability consequences. And until the community accepts the policies, it is difficult to discuss whether proposed delivery options will satisfy the goals in a suitably secure and stable manner.…
Improving and ensuring security and stability require balancing risks, benefits, and costs. While it is understood that the EWG Initial Report is a first attempt by the EWG to address these issues, the SSAC does not believe adequate explanations of the perceived benefits, risks, or costs, or how they were balanced has been provided. The EWG Initial Report describes some proposed solutions but does not always discuss why those solutions are justified. Instead, the report focuses on a specific outcome: a specific system with many features. The EWG Initial Report did not state what alternatives it considered and rejected and did not indicate the EWG’s methodology for developing its recommendations. Some of the items in the EWG’s list of “Desired Features and Design Principles” (pages 20-27) may be seen within the community as new policies, and some are feature requests and implementation choices that may be only some of the possible ways to execute on the policies. If the ICANN community does not accept some of the proposed policies, the features and implementation choices will necessarily change.
The SSAC believes a centralized meta-registry (e.g., the ARDS) is not the only solution to problems stated by the WHOIS Review Team, and it is unclear whether that specific solution will create net improvements when weighed against the risks. “
http://www.icann.org/en/groups/ssac/documents/sac-061-en.pdf
I personally will read that EWG final report to see if the EWG proposes a coherent set of WHOIS policies and under what basis the EWG justifies them. Based on the EWG’s November interim report and its response to the initial public comments, the EWG apparently believes that the centralized model (ARDS) is the way to go. I personally believe that that idea should receive robust debate and due diligence.
Among other things, SSAC recommended that a risk assessment be carried out. “The EWG agrees that risk/impact assessment should be conducted” (https://www.icann.org/en/groups/other/gtld-directory-services/summary-response-initial-12nov13-en.pdf), but AFAIK that risk assessment has not yet been planned because we first need to see what the EWG final report says. And then see above -- the scope of any risk assessments may be dependent on what the GNSO thinks. For example, if it is determined that the centralized ARDS idea is a non-starter for overriding policy or legal reasons, then why would anyone do a risk assessment of its implementation? In any case, I suggest the GSNO track and help direct the creation of risk assessments at the appropriate points.
In the meantime, ICANN has issued an RFI on behalf of the EWG: "to identify any organizations capable of accrediting users of the new [centralized] Registration Directory Service (RDS) now under consideration to replace the current WHOIS system....With this Request for Information, the EWG seeks to solicit responses from organizations that currently issue system access credentials to authorized members of their own community, using defined acceptance criteria...The purpose of this RFI is purely informational – that is, to inform the development of policies and procedures that may follow the EWG's Final Report. As a result, potential Respondents responding to any future RFP for the EWG Project will not be bound by the estimates, prices, or other information provided in response to this RFI."
https://www.icann.org/en/news/announcements/announcement-2-10feb14-en.htm
So that’s an interesting thing.
All best,
--Greg
From: gnso-ssr-bounces@icann.org [mailto:gnso-ssr-bounces@icann.org] On Behalf Of Mike O'Connor
Sent: Wednesday, February 12, 2014 8:41 AM
To: GNSO SSR List
Subject: [Gnso-ssr] discussion -- SAC061 -- SSAC Comment on ICANN’s Initial Report from the Expert Working Group on gTLD Directory Services
hi all,
here’s a thread to talk about the SSAC comment on EWG initial report.
here are a few questions. view them as a starting-point, not a rigid requirement. if you have a comment that falls outside of these questions, please go ahead and make your post. i’m just posting these to start conversation, not restrict it.
- what’s the current status of the EWG work?
- where are we in the process of establishing a registration data policy?
- who, if anybody, has taken these SSAC recommendations on board?
- is there anything that the GNSO, and/or the GNSO Council, should be doing in Singapore to help move this along?
- are there any other questions people would like to raise about this comment?
SAC061: SSAC Comment on ICANN’s Initial Report from the Expert Working Group on gTLD Directory Services