Hi. I agree with KC, Scott, Eric, others regarding KSK rollover – I think this is both a substantive and process issue for SSR2.

I reviewed the public comments on this (here and here) and considered the size, scope and standing of the stakeholders who made them. I also came to the opposite conclusion of ICANN staff who state that there’s a preponderance support for the roll as planned. While reasonable people can disagree, I think when the collective global businesses and Internet user groups in ICANN, as well Verisign (with its historic responsibilities in this area) ask that issues be addressed before proceeding, that deserves serious consideration and substantive response. By any standard, that did not occur.

For example, the Business Constituency raised a number of questions and issues (comment drafted by staff of Facebook and Google and unanimously adopted by the BC), yet only one issue was addressed in a cursory response that cites APNIC data analysis.

Best,

Denise

Denise Michel

Director, Domain Name System Strategy & Management

Facebook, Inc.

denisemichel@fb.com

On 9/13/18, 9:53 AM, "Ssr2-review on behalf of k claffy" <ssr2-review-bounces@icann.org on behalf of kc@caida.org> wrote:

my audio problems prevented me from hearing whatever Scott

might have added to his question on the call today, and i won't

have time to listen to that call again this week, so i'm hereby

asking Scott explicitly whether we covered his concerns adequately?

there is one more thing i wanted to mention but didn't want

to take up more time on the call. i encourage (really, please)

anyone with some time or some students to go through and analyze

the public comments for this KSK roll announcement -- there are

only ~22 of them)

https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_pipermail_comments-2Dksk-2Drollover-2Drestart-2D01feb18_&d=DwICAg&c=5VD0RTtNlTh3ycd41b3MUw&r=MWVuq3jZIw5gwhGdDf-HWNL4CEWIsdUnt9gOgplCArM&m=kPm-Mzza06FGs9hXRO_v922jOZWdUOVOhcCeaLkUQmg&s=MaPk6D0-93WbYLDjKi0Fl-3_bZhFxvyP0PpvOgEHVA0&e=

and to consider the size and scope of the stakeholders who

made them, and see if you come up with the same comclusion

ICANN drew that there is a "preponderance of support to roll".

i personally drew the opposite conclusion from the public

comments. i predict that if "the wrong things go wrong",

many people will go back and analyze these comments and

come to a different conclusion than ICANN did.

this i think is a serious SSR (and AT, and CCT, and even

RDS-WHOIS!) issue: that icannORG has responsibility for

evaluating feedback on its proposed policies before launching them.

as an academic, this felt to me like authors submitting a paper,

getting a bunch of critical feedback about the paper,

and then the authors deciding whether the paper gets published.

(or in ietf-land, whether a new RFC is standardized.)

i think icannORG is in an untenable position here, i am not

suggesting a deep dive into all the things they could have done

differently for the KSK roll. but our recommendations should

recognize CoIs inherent in the process of peer review of SSR issues,

which i suspect it will come up as we evaluate SSR1 recommendations.

i suspect several of us are already considering a recommendation

that includes support for someone independent from icann

determining whether icann has implemented all SSR2 recommendations.

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