Regarding the Proposed Issues Report on Registry Services Internet Service Providers and Connectivity Providers Constituency The ISPCP Constituency has a direct connection with a significant body of Internet stakeholders. Our customers - those people connected to the Internet - are the people and organizations most affected by unexpected changes in the Internet. This includes the introduction of new or modified registry services. Naturally, the ISPCP constituency needs to be a significant contributor to the Registry Services PDP process. ISPs are in a unique position to help guide policy development on new registry services. As those who have been largely responsible for the stability of the Internet, we believe that it is vitally important that the GNSO and its Council balance the need to move quickly on potential registry services while carefully thinking through operational and legal impacts of any recommendations. Our constituency actively supports the principle of maintaining the stability that the Internet has always enjoyed. Specifically, we believe that there is a requirement for technical, security and stability reviews for any newly proposed registry service. In addition, we believe that any significant change to registry services - that significantly changes or alters fundamental functions of DNS related services - should also be subject to an explicit, public, and extensive security, stability and technical review. No other group in the GNSO is as well positioned as the ISPCP to coordinate the technical evaluation of the protocol and operational impacts of a proposed change to registry services. Our constituency works daily with both the protocol standards that make the DNS work and is fully aware of the operational issues that are not part of the protocols, but which are embedded in the operational behavior of Internet protocols and services. Fundamentally, our constituency believes that: " No new registry service should be introduced without an explicit, public evaluation of its technical, stability and security implications; " No significant changes to registry services should take place that have the potential to significantly change the behaviour of underlying Internet services; " The ISPCP constituency should be a central contributor to any discussion of the technical implications of the introduction of new registry services; " All constituencies should be bound by the "principle of least astonishment" in the development of new services that affect the foundation protocols of the Internet; and, " All participants in GNSO constituencies should be bound by principles of operational security and stability for the Internet's user community. The ISP community must be a central part of the PDP process and any process that evaluates any future registry service offerings. If the ISPCP is not an explicit participant in the process, they must be able to participate by identifying appropriate expert analysts who can represent the operational interests of ISPs. On behalf of the ISPCP Constituency, Mark McFadden ISPCP Secretariat