Draft comments are inlaid as text, the attachment is the document on which the comments are to be prepared. Thank you. ---------- Forwarded message ---------- From: Sivasubramanian Muthusamy <isolatedn@gmail.com> Date: Mon, Jun 29, 2009 at 9:17 PM Subject: Fwd: Draft Comments on the Draft Implementation Plan for IDN ccTLDs 3rd Revision. To: idn-wg@atlarge-lists.icann.org Cc: cheryl <cheryl@hovtek.com.au>, At-Large Staff <staff@alac.icann.org> Hello, A draft comment on the 3rd revision of the "Draft Implementation plan for IDN ccTLDs" is forwarded to this working group for additions and comments. Please comment. Thank you Sivasubramanian Muthusamy IDN liaision. ---------- Forwarded message ---------- From: Sivasubramanian Muthusamy <isolatedn@gmail.com> Date: Sat, Jun 27, 2009 at 5:10 AM Subject: Draft Comments on the Draft Implementation Plan for IDN ccTLDs 3rd Revision. To: ALAC Internal List <alac-internal@atlarge-lists.icann.org> Cc: At-Large Staff <staff@alac.icann.org> ALAC Comments on Draft Implementation Plan for IDN ccTLD Fast Track Process Revision 3 Posted as an initial draft to start the comment process. The red line (actually it is in blue color) version of the 3rd revision of the draft implementation plan is attached to show changes During the ICANN meeting at Mexico, the ICANN Board encouraged the community to continue its work so that the implementation plan can be finalized and considered by the Board no later than at its annual meeting in 2009. ICANN has released the third revision of the Draft Implementation Plan for IDN ccTLDs. A public comment on this plan and the related papers is due on 15th July. Comments received will be used to revise the plan in preparation of a Final Implementation Plan which is expected to be provided for Board consideration no later than at the ICANN meeting in Seoul, 25-30 October 2009 1. In this revision detailed explanations of the entire evaluation process have been included together with flowcharts which points for clarity of expression and further progress towards implementation. ALAC notes these details in the Implementation plan as a sign that IDN TLDs are moving closer to implementation. 2. ALAC in agreement in principle that “the request for an IDN ccTLD cannot proceed through the Fast Track Process if the Panel or review team identifies that a requested string raises significant security and stability issues” ( 4.1) 3. In line with the IDNC WG Final Report, the external and independent DNS Stability Panel should be appointed to conduct technical due diligence and report to the ICANN Board. And in agreement with the IDNC WG report, the 3rd revision excludes the reference to the Registry Services Evaluation Process and the hint of DNSSEC but instead adds that “ICANN will secure the services of a competent technical panel (DNS Stability Panel) to make stability evaluations” And the report adds that “ICANN is finalizing the coordination of the DNS Stability panel and further details will be made available”. ALAC awaits further details. 4. The 3rd revision further enhances the role of Governments in the IDN ccTLD application process with its emphasis on “evidence of support” and the deletion of [evidenced of] “non-objection” as documentation requirements in the Preparation Stage. As in previous drafts, the 3 rd revision retains its position that such evidence of support needs to be from “the Minister with the portfolio responsible for domain name administration, ICT, foreign affairs or Office of the Prime Minister or President; or a senior representative of the agency or department responsible for domain name administration, ICT, Foreign Affairs or the Office of the Prime Minister.” While this stipulation reflects the positive involvement of Governments in the IDN TLD process and their concerns, and is in tune with ICANN's ccTLD delegation policies, ALAC notes with apprehension that International Domain Names as ccTLDs, together with ascii ccTLDs could enable governments to control access and curtail civil liberties. ALAC expresses concern about the emphatic reference to Governments which in effect makes the Governments as the requesters, either directly or indirectly. The description of the Preparation Stage process ( 5.1.1) specifies 1) 1. Support from the relevant government or public authority 2) Support ... by the relevant government, ALAC expresses concerns on this continued and emphatic references to Governments as total deviation from the gTLD processes and principles. 5. ALAC is committed to multi-stakeholder approach and notes postively the inclusion of the passage “The application should demonstrate there has been community dialogue regarding which string is the appropriate representation of the country in the selected string(s) and/or language(s)/script(s), and that appropriate stakeholders have been involved in the decision making process.” and feels that this passage alone could address the concerns of Governments and all stakeholders. 6. Alac welcomes the proposed submission system for the string evaluation stage (Stage 2) as a web-based form that identifies the information necessary. ALAC feels that web based processes would be of help in enabling swift submission of the required information and would lead to transparency even in the level of applications as submitted. 7. ALAC notes that the 3rd revision excludes portions of Module 7 of the 2nd revision purportedly "to only contain discussions of outstanding issues". Topics deleted from the previous versions of the plan are “considered solved” though included elsewhere in the plan “as deemed necessary”. Module 7: Discussion of Additional Topics has been entirely deleted in the third revision with the observation that “most of the topics remaining in this module relate directly to the overarching requirements to Preserve the security and stability of the DNS and Ensure compliance with the IDNA protocol and IDN Guidelines.The remaining topics included have all been addressed in supporting papers to this plan. (But the hypertext links to the documents are not included in the draft implementation Plan document.) Alac wishes to comment that the topics could have been listed under a separate section of the report as topics considered solved to retain the extent and depth of topics related to the IDN TLD process. 8. ALAC feels that the topic of “Financial Contribution” or cost recovery, for instance could not be considered as a topic that can be “considered solved”. ALAC feels that more discussions are needed on the details of the proposed cost recovery model. Sivasubramanian Muthusamy ALAC IDN liaison.