SAC114 - SSAC Comments on the GNSO New gTLD Subsequent Procedures Draft Final Report
Abstract
The SSAC makes the following comments and recommendations. For the full and
official recommendations see Section 4 of this publication.
● First, the SSAC believes that the introduction of more gTLDs to the root namespace is
not consistent with ICANN’s mission and commitment to keep the Internet secure, stable,
and interoperable. The fundamental question from the SSAC’s security and stability
perspective is whether adding more generic top-level domains (gTLDs) to the root
namespace should remain a primary response to furthering the overall objectives of
ICANN, namely “keeping the Internet secure, stable and interoperable. [ICANN]
promotes competition and develops policy on the Internet's unique identifiers.”2 This
comment is not a criticism of the Final Report or the community effort, but the SSAC
thinks now is a good time for the ICANN Board to address this question.
The SSAC recommends that the ICANN Board initiate a fundamental review to
determine whether continuing to increase the number of gTLDs is consistent with
ICANN’s strategic objective to “evolve the unique identifier systems in coordination and
collaboration with relevant parties to continue to serve the needs of the global Internet
user base.”3 This review should be considered an input towards updating ICANN’s
strategic goals in conjunction with implementing the CCT Review Team’s
recommendations (see Recommendation 1).
● Second, given a general intent to proceed with this program in any case, there is a clear
need to add greater levels of not only process oversight, but also a systemic consideration
of the program’s impact, attendant risks and appropriate mitigations to the DNS itself.
The systemic considerations would include addressing, monitoring and mitigating
impacts on the entire DNS resolution chain (e.g., root servers, DNS recursive resolver
performance) and services that provide and/or are dependent upon it.
In addition, numerous items relating to risks, outcomes, and impacts of increasing the
gTLD namespace need to be measured and analyzed to better understand some of the
fundamental questions considered by the Working Group as well as areas it did not
explore. The SSAC agrees with the measurements proposed by the Working Group
Recommendations 7.1 - 7.5 and suggests additional goals and measurements.
The SSAC recommends that, as part of the process for creating new gTLDs, ICANN
develop and adopt a protocol for measuring progress against stated goals of the program
and thresholds, which if crossed, may require mitigation actions. Such measurements and
actions should consider the entirety of the DNS ecosystem (see Recommendation 2).
● Third, on the issue of DNS abuse, while the SSAC agrees that a holistic approach to DNS
abuse issues has merit, we note that security threats and attendant abuse of the DNS
remain a constant and rapidly evolving challenge, and that ICANN recognizes “Domain
name abuse continues to grow” as a Strategic Risk to the achievement of its Strategic
Objectives. Waiting until efforts to mitigate DNS abuse can be equally applied to all
existing and new gTLDs effectively cedes the ground to malicious actors who can depend
upon a long policy development process to hinder meaningful anti-abuse measures.
The SSAC recommends that the ICANN Board, prior to launching the next round of new
gTLDs, commission a study of the causes of, responses to, and best practices for the
mitigation of the domain name abuse that proliferates in the new gTLDs from the 2012
round. This activity should be done in conjunction with implementing the CCT Review
Team’s relevant recommendations. The best practices should be incorporated into
enforced requirements, as appropriate, for at least all future rounds (see Recommendation
3).
official recommendations see Section 4 of this publication.
● First, the SSAC believes that the introduction of more gTLDs to the root namespace is
not consistent with ICANN’s mission and commitment to keep the Internet secure, stable,
and interoperable. The fundamental question from the SSAC’s security and stability
perspective is whether adding more generic top-level domains (gTLDs) to the root
namespace should remain a primary response to furthering the overall objectives of
ICANN, namely “keeping the Internet secure, stable and interoperable. [ICANN]
promotes competition and develops policy on the Internet's unique identifiers.”2 This
comment is not a criticism of the Final Report or the community effort, but the SSAC
thinks now is a good time for the ICANN Board to address this question.
The SSAC recommends that the ICANN Board initiate a fundamental review to
determine whether continuing to increase the number of gTLDs is consistent with
ICANN’s strategic objective to “evolve the unique identifier systems in coordination and
collaboration with relevant parties to continue to serve the needs of the global Internet
user base.”3 This review should be considered an input towards updating ICANN’s
strategic goals in conjunction with implementing the CCT Review Team’s
recommendations (see Recommendation 1).
● Second, given a general intent to proceed with this program in any case, there is a clear
need to add greater levels of not only process oversight, but also a systemic consideration
of the program’s impact, attendant risks and appropriate mitigations to the DNS itself.
The systemic considerations would include addressing, monitoring and mitigating
impacts on the entire DNS resolution chain (e.g., root servers, DNS recursive resolver
performance) and services that provide and/or are dependent upon it.
In addition, numerous items relating to risks, outcomes, and impacts of increasing the
gTLD namespace need to be measured and analyzed to better understand some of the
fundamental questions considered by the Working Group as well as areas it did not
explore. The SSAC agrees with the measurements proposed by the Working Group
Recommendations 7.1 - 7.5 and suggests additional goals and measurements.
The SSAC recommends that, as part of the process for creating new gTLDs, ICANN
develop and adopt a protocol for measuring progress against stated goals of the program
and thresholds, which if crossed, may require mitigation actions. Such measurements and
actions should consider the entirety of the DNS ecosystem (see Recommendation 2).
● Third, on the issue of DNS abuse, while the SSAC agrees that a holistic approach to DNS
abuse issues has merit, we note that security threats and attendant abuse of the DNS
remain a constant and rapidly evolving challenge, and that ICANN recognizes “Domain
name abuse continues to grow” as a Strategic Risk to the achievement of its Strategic
Objectives. Waiting until efforts to mitigate DNS abuse can be equally applied to all
existing and new gTLDs effectively cedes the ground to malicious actors who can depend
upon a long policy development process to hinder meaningful anti-abuse measures.
The SSAC recommends that the ICANN Board, prior to launching the next round of new
gTLDs, commission a study of the causes of, responses to, and best practices for the
mitigation of the domain name abuse that proliferates in the new gTLDs from the 2012
round. This activity should be done in conjunction with implementing the CCT Review
Team’s relevant recommendations. The best practices should be incorporated into
enforced requirements, as appropriate, for at least all future rounds (see Recommendation
3).
Research Areas
