Executive Summaries: ALAC Statements (Comments, Correspondence, and Advice) (November 2017 to September 2024)
THIS PAGE HAS BEEN RETIRED AS OF SEPTEMBER 2024. PLEASE VISIT THE INDIVIDUAL AT-LARGE WORKSPACE OF EACH COMMENT, CORRESPONDENCE OR ADVICE ON THE At-Large Policy Advice Development Page FOR EACH SUBMISSION'S EXECUTIVE SUMMARY.
The At-Large Advisory Committee (ALAC) is the primary organizational home for the voice and concerns of the individual Internet end user.
Below is a compilation of executive summaries of ALAC policy and operational statements since ICANN60, providing the Internet end user perspective of ICANN policy.
ALAC Statement Definitions
» Comment is an ALAC statement providing input and feedback in the ICANN public comment process. Public Comment is a key part of the policy development process (PDP), allowing for refinement of recommendations before further consideration and potential adoption. Public Comment is also used to guide implementation work, reviews, and operational activities of the ICANN organization.
» Advice is an ALAC statement issued to the ICANN Board as formal advice, representing the interests of the Internet end user community. Read more here.
» Correspondence is all formally drafted, signed communications pertaining to non-confidential topics within ICANN’s remit and that are directed to the ICANN Board, CEO, Executives or staff. View ICANN Correspondence.
References
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Date Submitted to ICANN Board or Public Comment | ALAC Statement | Executive Summary |
|---|---|---|
30 September 2024 | Comment: At-Large Workspace: Transfer Policy Review Working Group Initial Report | The ALAC supports many of the recommendations as drafted by the GNSO Transfer Policy Review. However, the ALAC does have concerns regarding Recommendation #26 and recommends having a "standalone" policy for Change of Registrant Data (CORD) does not recommend removing an inter-Registrar transfer lock after a “Material Change” of registered Registrant Data. Additionally, the ALAC believes Registered Name Holders should be allowed to initiate a Transfer Dispute under the revised Transfer Policy. |
17 September 2024 | Comment: At-Large Workspace: Draft ICANN Strategic Plan and Operating Plan Framework for FY26-30 | The At-Large Advisory Committee (ALAC) and the At-Large Community appreciate the opportunity to comment on the Draft ICANN FY26-30 Strategic Plan and the Draft Operating Plan Framework. Our general response to this public comment shows our strong support for the new style and format of the Draft ICANN Strategic Plan and Operating Plan Framework for FY 26-30 documents. We especially appreciate the simplicity, clarity and visuals which contribute to a very positive overall experience. We would like to also share the methodology we used to ensure active community engagement in this exercise. We created a community poll based on the ICANN’s Public Comment standard form questions, supplemented with material edited from the draft documents and translated in three languages (English, France and Spanish). This approach was unique to this activity and aligns with the strategies outlined in the strategic plan to foster greater community involvement. We received forty responses to the poll. The results are provided in two parts with answers to each question presented in the ICANN’s Public Comment standard form, and verbatim excerpts of the results of our At-Large Community Poll, presented in the general comments section. |
16 September 2024 | Comment: At-Large Workspace: IRP-IOT – Proposed updates to the IRP Supplementary Procedures | The Independent Review Process (IRP) is a key accountability mechanism under ICANN’s Bylaws, which provides for third-party review of Board or Staff actions or inactions which are alleged to exceed ICANN’s Mission or otherwise be inconsistent with its Articles or Bylaws. The procedural rules for the IRP are set out in Supplementary Procedures. Shortly following the amendment of ICANN’s Bylaws as a result of the IANA Transition, the IRP - Implementation Oversight Team (IOT), was formed to ensure the supplementary procedures align with international arbitration standards and are fair and understandable. This document outlines the At-Large Advisory Committee's (ALAC) response to the proposed updates to the Independent Review Process (IRP)-Implementation Oversight Team (IOT) Supplementary Procedures, published for public comment on July 3, 2024. The matter of panel selection and conflict of interest is of significant importance to the Internet community, including end-users, because it directly impacts the fairness and impartiality of the Independent Review Process, which ultimately safeguards the interests of the global Internet community. Ensuring that the process is transparent, accessible, equitable, and free from conflicts of interest helps build trust in ICANN’s accountability mechanisms. Greater clarity and consistency regarding the rules covering timing (including time to file, deadlines for filing, and exceptions) and a better structured, defined process for initiating and managing IRPs will benefit end users by ensuring that disputes are resolved efficiently and without unnecessary procedural barriers. Enhancing the rules regarding translation services and amicus curiae appearances will ensure broader participation and greater fairness for participants. Therefore, ALAC strongly supports the proposed updates to Rules 3, 4A, 4B, 4C, 4D, 5B, and 7, viewing them as substantial improvements to the IRP-IOT Supplementary Procedures. While ALAC endorses these changes, it also underscores the importance of addressing the recommendations concerning Rules 3.3, 3.5, and 4B, 4D as discussed below.
After a comprehensive review and discussion within the At-Large Operations, Finance and Budget Working Group (OFB-WG), the draft ALAC comment was developed and subsequently ratified by the ALAC through an online vote. This comment reflects the collective insights and recommendations of the ALAC and the wider At-Large community, emphasizing the need for an accessible, balanced and equitable IRP process that serves the interests of all stakeholders. The ALAC appreciates the opportunity to contribute to this critical discussion and urges ICANN to consider these recommendations to strengthen the IRP's role as a key accountability mechanism within the global Internet governance framework. |
16 September 2024 | Comment: At-Large Workspace: Proposed Fundamental Bylaws Amendments Related to Grant Program | The ALAC strongly supports the proposed amendment to Article 4, Sections 4.2 and 4.3 of the ICANN Bylaws whereby ICANN’s Reconsideration and Independent Review Processes cannot be used to challenge, dispute, or seek reconsideration for any decisions made by ICANN, as they relate to an individual application made in the ICANN Grant Program. This bylaw amendment does not change the Bylaws governing any other part of those Accountability Mechanisms. These proposed Bylaw changes concern decisions made in respect of the ICANN Grant Program. The ALAC agrees that no reconsideration or review shall be granted if the dispute relates to decisions made to approve or not approve an application in the ICANN Grant Program. The ALAC is comfortable with how the proposed Bylaw amendment is presented, in the Public Comment since this change only relates to the ICANN Grant Program and no other programs, decisions, or actions by ICANN. |
12 September 2024 | Comment: At-Large Workspace: gTLD IDN Tables Review Process When Reference LGR is not available | The ALAC strongly supports enabling any community to have its entire online space in its own language, in line with digital inclusivity and ICANN’s strategy for IDNs. The ALAC believes Reference – Label Generation Rules (LGRs) are essential for preventing end-user confusion and ensuring the security of domain names. The ALAC believes the proposed process will play a crucial role in enabling all communities to have a presence in the domain name space, fostering digital inclusivity and representation. |
26 August 2024 | Comment: At-Large Workspace: Preliminary Issue Report on Latin Script Diacritics | The ALAC and At-Large community strongly supports the initiative of starting a single issue Policy Development Process to create consensus policy recommendations that would enable the use of diacritics. |
19 August 2024 | The ALAC and At-Large community finds the language falling short of the Final Report recommendations 18.4 and 18.6 from Topic 18: Terms and Conditions, as well as Topic 17: Applicant Support (to ASP). In particular to ASP, the ALAC believes there is a need to ensure that the terms and conditions regarding eligibility of applicants which apply at the time the ASP application window opens must be preserved right up till when the applicant has the TLD successfully delegated to it. The ALAC also believes that the entire intent of the SubPro Final Report Implementation Guidance 17.17 should be incorporated as a Term and Condition for ASP as it is important for applicants to understand and accept the restrictions as enforceable by ICANN. The ALAC also seeks clarification and/or suggests several changes to a number of clauses in the ASP terms and conditions. Regarding the RSP Evaluation Program, the ALAC, similar to the ASP suggestions, recommends reinstating the provisions from the 2012 AGB around rights and obligations of an Applicant, and providing clarification in proposed clause 5 regarding who “ICANN Affiliates” are. | |
12 August 2024 | Correspondence: At-Large Workspace: Correspondence regarding At-Large Input on Applicant Support Program Use of Auction Proceeds | The ALAC and At-Large community continue to believe the ASP to be an essential part of the Next Round and remain steadfast in the belief that the Board should continue to prioritize the ASP. The ALAC received strong support for the Board’s proposed use of US$ 5 million of auction proceeds to partially fund the ASP for the New gTLD Program: Next Round on the basis that sum of auction proceeds will be used to support worthy applicants, including a group targeted by the Cross-Community Working Group on New gTLD Auction Proceeds (CCWG-AP) (i.e. applicants from underdeveloped and underserved regions). However, several members of the At-Large Community voiced concerns regarding how this request was made, as it is outside of the recommendations provided by the CCWG-AP and concerned about the ease with which the Board has abandoned its previous guarantee that it would not use the auction funds again outside the approved recommendations of the CCWG-AP. |
02 July 2024 | Comment: At-Large Workspace: Policy Status Report: GNSO Policy & Implementation Working Group Recommendations | The ALAC and At-Large generally endorses and supports the Policy Status Report (PSR): GNSO Policy & Implementation Working Group Recommendations, finding it quite detailed and well-considered. The ALAC and At-Large through our direct inclusion in the implemented processes, as well as our review of the PSR, that all the processes that have been implemented to date have proved useful and that we agree with the assessment of these processes in the PSR that ‘...these processes have proved effective in supporting and enhancing GNSO Policy and Implementation efforts,...' |
21 May 2024 | Comment: At-Large Workspace: Phase 2 Initial Report of the EPDP on Internationalized Domain Names | The ALAC supports all twenty preliminary recommendations and implementation guidelines mentioned in the initial report. Additionally, the ALAC suggest four text improvement opportunities and mentions three cases where the EPDP Team did not provide any recommendations to which the ALAC has provided suggested guidance. |
29 April 2024 | Correspondence: At-Large Workspace: ALAC-GAC Joint Letter regarding the Applicant Support Program | The ALAC and the GAC agree that the ASP continues to be an area of importance and that it should be prioritized by the Board. To support a successful program, the ALAC and GAC would like to see commitments to alleviate the financial burden on applicants through ASP to the maximum extent possible, to prioritize outreach to applicants from global underserved regions, apply a holistic approach in facilitating adequate and needed support for ASP applicants,and to support the longer-term success of ASP-qualified applicants. |
29 April 2024 | Comment: At-Large Workspace: Proposed Renewal of the Registry Agreement for the .XXX top-level domain (TLD) | The ALAC appreciates ICANN org's efforts to standardize contracts for compliance enforcement purposes. The ALAC is concerned about the formation and implementation of commitments made by potential or existing Registry Operators that are perceived by the community as unimplemented or unilaterally discarded by the Registry Operator or unenforced by ICANN Compliance. |
15 April 2024 | Correspondence: At-Large Workspace: Proposed Update to Recommendation 7 by the New gTLD Auction Proceeds Cross-Community Working Group (CCWG-AP) | The ALAC confirms that the Board's interpretation of the CCWG-AP Recommendation is correct and that removing "from the Independent Project Applications Evaluation Panel" from recommendation 7 is in line with both the intent and understanding of the recommendation. |
15 April 2024 | Comment: At-Large Workspace: Proposed Bylaws Updates to Limit Access to Accountability Mechanisms | The ALAC strongly supports the proposed Fundamental Bylaw amendment and commends the Board for revising the CCWG New gTLD Auction Proceeds recommendation to form a more general Bylaw should a comparable accountability mechanism limitation be needed in the future. The ALAC has one concern regarding the Bylaw amendment and recommends appending a sentence regarding the accountability mechanisms. |
10 April 2024 | This ALAC statement comments on the NETmundial+10 consultation which aims to gather contributions from all stakeholder groups regarding the various policy issues in the scope of the event. | |
10 April 2024 | Comment: At-Large Workspace: String Similarity Review Guidelines | The ALAC has various concerns regarding potential conflicts between new gTLD names and commends the authors of the String Similarity guidelines for addressing these conflicts in its guidelines. The ALAC further notes their concern regarding the use of Underlining and believes underlining should be considered during the String Similarity Review. |
02 April 2024 | Comment: At-Large Workspace: Review of the Draft Applicant Support Program (ASP) Handbook – New gTLD Program | The ALAC believes that ASP funds should not be strictly limited to allocation on a first come, first served basis and should be amenable to enlarging the budget if needed. The ALAC believes the Section 1 (“Introduction”) accurately reflects the relevant policy recommendations on Applicant Support. The ALAC believes Section 2 ("Overview") and Section 3 ("Applicant Support Program Timeline") reflects the relevant policy recommendations on Applicant Support but with suggested clarification. Additionally, the ALAC believes Section 4 ("Reduction of New gTLD Program Application and Evaluation Fees"), Section 5 ("Applicant Eligibility and Evaluation Criteria"), and Section 7 ("ASP Application Evaluation") do not accurately reflect the relevant policy recommendations on Applicant Support. |
22 March 2024 | Comment: At-Large Workspace: Timing and Potential Deferral of ATRT4 and Related Community Engagement | The ALAC advises against any delay in convening ATRT4. |
21 March 2024 | Comment: At-Large Workspace: Proposed Top-Level Domain String for Private Use | The ALAC supports the reservation of .INTERNAL for private use. |
19 March 2024 | Comment: At-Large Workspace: Proposed Language for Draft Sections of the Next Round Applicant Guidebook | The ALAC agrees that the language for the Predictability Framework, Conflicts of Interest Process for Vendors and Subcontractors, Universal Acceptance, and Reserved and Blocked Names is consistent with the relevant SubPro Final Report recommendations for these topics. The ALAC does not believe the language for Code of Conduct and Conflict of Interest Guidelines, Applicant Freedom of Expression, and Geographic Names are consistent with the relevant SubPro Final Report recommendations for these topics. |
12 March 2024 | Comment: At-Large Workspace: Phase 1 Final Report of the EPDP on Internationalized Domain Names | The ALAC supports the steps taken by the working group to apply the conservatism principle to moderate applicant's seeking to one or more allocatable variant labels. The ALAC believes that applicants should be discouraged from applying for strings in scripts not yet integrated into the RZ-LGR. |
28 February 2024 | Comment: At-Large Workspace: Draft NCAP Study 2 Report and Responses to Questions Regarding Name Collisions | The ALAC supports the recommendations and findings provided in the Name Collision Analysis Project (NCAP) Discussion Group’s study 2 report and the detailed responses to the Board’s questions regarding name collisions. The ALAC agrees that name collision is a risk management issue and supports the NCAP DG’s call for an independent and neutral Technical Review Team. The ALAC notes that there are recommendations that, if adopted by the ICANN Board, must be implemented expeditiously as to not delay the next round of new gTLDs. |
23 February 2024 | Correspondence: At-Large Workspace: PICs / RVCs | The ALAC provided its response to the Board consultation on PICs/RVCs. The ALAC provided input on whether an applicant can proceed without a commitment when they have received an objection, third-party monitoring, changes to the implementation framework, improvements to dispute resolution procedures, and content restrictions as it relates to the ICANN Bylaws. |
12 February 2024 | The ALAC and At-Large provided comments on selected operating initiatives, functional activities, the ICANN FY25 budget, IANA FY25 budget, and provided details regarding the FY25 At-Large Funding Requests (AFR) Proposals. | |
12 February 2024 | Comment: At-Large Workspace: Draft PTI FY25 Operating Plan and Budget | The ALAC and At-Large acknowledge the efforts that ICANN org devotes to developing financial and operational plans for the ICANN community and understands that community participation in ICANN org’s annual planning process as a foundation for ICANN’s public accountability. The ALAC and At-Large believe that it would be more prudent to provide in the PTI FY25 Budget a forecast for this additional headcount, in order to have budgeted funds earmarked for this potential expense. |
08 February 2024 | Comment: At-Large Workspace: Draft Final Report of the 2023 Africa Domain Name Industry Study | The ALAC and AFRALO supports the draft final report of the 2023 Africa Domain Name Industry Study. The ALAC highlights several key points about the study, including key features of the African DNS market, the influence of politics on telecommunications and the internet, barriers to growth, and the analysis of domain name uptake across the continent. The ALAC supports the research team's establishment of a DNS observatory and promotion of Internet eXchange Points (IXP) in Africa. |
27 November 2023 | Comment: At-Large Workspace: Pilot Holistic Review Revised Draft Terms of Reference | The ALAC and At-Large continue to support the recommendations made by ATRT3 regarding Reviews, Holistic Review(s), and the implementation of Continuous Improvement Programs. The ALAC is in favor of having the 'pilot' holistic review started as quickly as possible and proposes that ICANN org consider the benefits of running various preparatory phases as outlined in the Terms of Reference. |
09 November 2023 | Advice: At-Large Workspace: Closed Generics Advice to the Board | The ALAC fully supports the GAC's advice, which states that "Prior to the next round of New gTLDs, to ensure that the forthcoming Applicant Guidebook clearly states that Closed Generic gTLD applications will not be considered." Additionally, the ALAC believes that the differences among the various parties on what would satisfy a public interest or the global public interest may be irreconcilable, and that the benefit of Closed Generic gTLDs are not worth expending more community time and ICANN resources. |
28 September 2023 | Comment: At-Large Workspace: ccNSO Proposed Policy for a Specific ccTLD Related Review Mechanism | The ALAC and At-Large community are supportive of the important role that the ccTLDs Managers serve within the ccNSO and the broader ICANN community. However, the ALAC believes that the proposed amendments to the ICANN Bylaws should be expanded to provide additional standing for “significant stakeholders” and “relevant government” under the proposed review mechanism. |
27 September 2023 | Comment: At-Large Workspace: ccNSO PDP4 Initial Report on the (de-)selection of IDNccTLDs | The ALAC and the At-large community express their support of the proposed recommendations. The ALAC would like to draw attention to the ICANN Board’s resolution regarding managing the IDN variant TLDs, requesting a consistent solution is developed for both IDN variant ccTLDs and IDN variant gTLDs. The ALAC considers the Board’s resolution not only important for ensuring consistent implementation and rationale but also for maintaining consistent user experiences. |
18 August 2023 | Correspondence: At-Large Workspace: ALAC Proposal for Subsequent Procedures Recommendation 17.2 on Applicant Support | The ALAC is pleased to submit its proposal on resolving two concerns regarding Subsequent Procedures Recommendations 17.2 on Applicant Support. The ALAC reinforces its position that the Applicant Support Program is an essential component of the New gTLD Program. The ALAC believes the approach to providing applicant support services must be holistic in order to be able to support deserving applicants throughout the application and evaluation processes up to approval, and preferably including support for the post-approval stage. The ALAC believes that there should be no payment made directly to third party services providers. Additionally, the ALAC believes that the optimal way to implement a holistic ASP is by way of an ASP Incubator. |
25 July 2023 | Correspondence: At-Large Workspace: ALAC Input on Transfer Policy PDP Charter Recommendations Phase 2 G3 | The ALAC fully supports the efforts of the Transfer Policy Working Group to facilitate the prompt and secure transfer of domain names to a registrar/reseller of their choice. The ALAC disagrees with the preliminary draft recommendation as it presupposes an outcome that is detrimental to the interests of individual internet users. The ALAC is of of the view that Registrants should be given the opportunity to initiate the Registrar Transfer Dispute Resolution Policy and finds it unreasonable that the only option for Registrants is to take inter-registrar transfer disputes to court.
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15 July 2023 | Correspondence: At-Large Workspace: ALAC Input on Closed Generics Draft Framework | The ALAC is of the view that the Closed Generics Draft Framework lacks sufficient intent and clarity to be operationally useful, though a follow on PDP may add sufficient clarity. The ALAC is of the view that the framework is both too complex to be useful to public interest organizations and too vague to disallow anticompetitive outcomes that drove opposition to closed generics in the previous round. |
13 July 2023 | Comment: Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations | The ALAC and At-Large community strongly supports the RA an RAA amendments to modify DNS abuse contract obligations. The ALAC and At-Large community appreciate the accompanied Draft ICANN Advisory, which provided guidance and expectations for action by registrars and registries to ensure compliance with the new contractual terms. The ALAC and At-Large community commend the Registrar Stakeholder Group, the Registry Stakeholder Group and ICANN Org and hope that there continues to be a collective effort to effectively combat DNS Abuse both as currently defined, and as it may evolve over time. |
22 June 2023 | Correspondence: Correspondence - Latin Script RZ-LGR Variants | ALAC Chair to GNSO Chair (.Quebec) | The ALAC brings to the attention of the GNSO Council the diacritic issue with .Québec and the Latin script Root Zone Label Generation Rules' (RZ-LGR) preclusion of some perceived variants. |
19 June 2023 | Comment: Phase 1 Initial Report on the Internationalized Domain Names EPDP | In general, the ALAC supports the preliminary recommendations and implementation guidance proposed by the EPDP in its Phase 1 Initial Report, and highlights specific comments of support and concerns. These specific comments were attached as a PDF to supplement the ALAC’s responses submitted via this guided form on the following topics: Root Zone - Label Generation Rule (RZ-LGR), Same-Entity Principle, Application Fee Regime for Variants, and the Glossary. |
29 May 2023 | Comment: Bylaws Amendments and Documents to Implement the NomCom2 Review | At a high level, overall, the At-Large Community and the At-Large Advisory Committee (ALAC) are supportive of the
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25 May 2023 | Comment: Proposed Renewal of the Registry Agreement for .NET | The ALAC and At-Large community are supportive of the majority of updates to the .NET contract including provisions concerning RDAP; DNS Abuse mitigation commitments; and use, by ICANN, of the Bulk Registration Data Access (BRDA) for research. We have recommendations related to the boundaries of consensus policy with respect to .NET, the need for a comparison between .NET and the Base Registry Agreements (RAs), and the need to revisit Registry Operator participation in economic studies (including .NET). |
13 February 2023 | Comment: At-Large Workspace: Draft FY24–28 Operating & Financial Plan and Draft FY24 Operating Plan & Budget | The ALAC thanks ICANN org for the important reduction of pages of this Operational Plan & Budget, without losing the explanations of the budget, operational plans, and initiatives. As it has been in the last years, it is presented in a very readable format, with bookmarks embedded in the document. We also appreciate the inclusion of the budget ‘highlights’ that provide a good summary of the two documents for those without the time to read both documents. The At-Large community provided comments on the following areas: FINANCIAL PLANS AND BUDGETS
OPERATING INITIATIVES
FUNCTIONAL ACTIVITIES
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Jan 23, 2023 | The ALAC commends the Country Code Names Supporting Organization (ccNSO) Policy Development Process Review Mechanism Working Group on completing the initial report and would like to offer its support to the included recommendations. The ALAC would like to stress the importance of ensuring that any review mechanism process does not result in end user confusion or inconvenience. Country Code Top-Level Domain (ccTLD) end users must be prioritized when performing any review mechanism. Commitment to due process and policies such as these will help ensure the consideration of end users. | |
Jan 20, 2023 | Correspondence: BC/IPC/ALAC to the ICANN Board: Improvements to 2013 Registrar Accreditation Agreement (RAA) and Current Registry Agreement (RA) | We request that ICANN Org follow precedent with regard to transparency to the community and the opportunity to contribute to negotiation efforts. We do not request or expect a role in the negotiating process itself; however, the community deserves a voice in matters of public interest such as the RAA and RA. |
Jan 19, 2023 | Correspondence: ALAC to the ICANN Board: Comments and Concerns on the SubPro Operational Design Assessment (ODA) | The At-Large Advisory Committee (ALAC) thanks ICANN org for its enormous effort preparing the ODA. While analysis of the ODA is ongoing, we thought it worthwhile to provide some high level commentary, in the run up to the ICANN Board discussion of the ODA. Outlined in this letter are a number of high-level comments and concerns related to ALAC priority topics covered by the ODA as well as specific concerns regarding the differences between Option 1 and Option 2. Ahead of ICANN76, the ALAC is conducting an analysis of the ODA in comparison to its 2021 Advice to the ICANN Board on Subsequent Procedures and its related response to the ICANN Board’s Clarifying Questions. The objective of this analysis was to review several key priority topics and identify
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Dec 1, 2022 | Comment: Initial Report on the Second CSC Effectiveness Review | The ALAC and At-Large community support almost all of the recommendations in the Initial Report, with a few minor exceptions:
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Nov 30, 2022 | The At-Large Advisory Committee (ALAC) has comments and concerns in regards to the following sections of this Public Comment proceeding:
This policy sets the necessary foundation for the processing of generic top-level domain (gTLD) registration data. Namely, the purposes for the processing of the gTLD registration data and data elements required to be collected, published and redacted, it is important to accurately implement this policy in due time. We would like to note that according to recommendation number 18, response time to disclosure requests were meant to be finalized through the requirements set during the implementation stage. As such we do not agree with section number 10.6 as it sets responses to urgent lawful disclosure requests to up to two business days. This would mean if a request comes on a weekend, the response to an urgent lawful disclosure request could be provided after four days. We need to remember that urgent requests are requests related to circumstances that pose an imminent threat to life, serious bodily injury, critical infrastructure, or child exploitation. Therefore, the response time set in section 10 in relation to urgent requests will not satisfy the purpose of the request. The ALAC also notes that in accordance with recommendation number 18, the ALAC does not expect that the implementation of Section 10 (Reasonable requests) will prevent or hinder the undergoing work in relation to a standardized system for access/disclosure (SSAD). | |
Nov 17, 2022 | The ALAC and At-Large are in support of the budgets as proposed, with a few exceptions. The ALAC has concerns regarding the Public Technical Identifiers (PTI) headcount, travel expenses, and budget. They are also concerned that critical functions of the PTI are being passed to professional services. Further explanation is included in our statement below. | |
Nov 15, 2022 | The ALAC has only one request for the Generic Names Supporting Organization (GNSO) in regards to the Council Committee for Overseeing and Implementing Continuous Improvement (CCOICI). We request that the "At-Large Community" be included in addition to the existing option of “At-Large Advisory Committee (ALAC)” within the CCOICI’s Review of Working Group Self Assessment Requirements document, under item 3, “Primary Organizational Affiliation.” | |
Nov 10, 2022 | The At-Large Advisory Committee (ALAC) and the At-Large community are clear on the purpose and potential of recommendation 3.5 from the Third Accountability and Transparency Review Team (ATRT3). As with other recommendations made by ATRT3, this recommendation is fully supported, as outlined in the January 2020 ALAC statement. The ALAC and At-Large community strongly endorse the principle of a regularized Holistic Review as part of the overall ICANN org Review cycle. Therefore, we support the proposed draft Terms of Reference (ToR) while the Holistic Review is in this pilot phase. The ALAC and At-Large welcome this opportunity to respond to the specific questions posed in the call for Public Comment. Please note that the ALAC and At-Large:
In summary, the ALAC/At-Large show strong support for the process and see this Public Comment proceeding as an opportunity for the ALAC/At-Large to contribute comments that help ensure a rapid start to the long-awaited Holistic Review.
Related: ALAC statement on ATRT3 (January 2020). | |
Oct 31, 2022 | Comment: Universal Acceptance Roadmap for Domain Name Registry and Registrar Systems | The ALAC believes that the Roadmap will highlight the issue of UA compliance within the registry and registrar communities, and will assist the community to achieve compliance. However, there are a few areas where the ALAC believes the Roadmap could be improved: The report has chosen not to consider the issue of Internationalized Domain Name (IDN) variants. There is no mention of the role of resellers. The report does not take into account the continuing changes to access mechanisms for registration data. |
Aug 2, 2022 | Comment: Initial Report on the Transfer Policy Review - Phase 1(a) | The At-Large community is focused on the Registrant and End-User perspective, and supports processes and policies that make an Inter-Registrar Transfer and a Change of Registrant simple, safe and secure. At-Large supports a transfer policy that makes an Inter-Registrar transfer of a registered domain name as secure and fast as possible. At-Large believes that the charter questions and the work done in the TPR WG, as written in the Initial Report for Phase 1a, mostly support this position. |
Jun 3, 2022 | In light of the ICANN Board's ongoing focus on NIS2 issues and the EPEP Phases 2A recommendation, the ALAC is prepared to withdraw this item of advice and re‐issue it should the situation warrant it in the future. Related: EPDP Phase 2A Policy Recommendations for ICANN Board Consideration (13 Jan 2022) | |
May 31, 2022 | Response: ALAC Response to ICANN Org Clarifying Questions on the ALAC Advice on the Travel Acknowledgement | The additions ICANN org made to the FAQs do not modify the initial comments contained in the ALAC Advice on the ICANN74 Travel Acknowledgement (May 2022). The ALAC Advice was concerned with the waiver itself -- which is a stand alone legal document. Objections to the waiver centered around the fact that it went well beyond health and safety conditions related to Covid-19 and participants were asked to waive any and all rights to seek redress from ICANN, regardless of the situation under consideration. The FAQs address health and safety measures put in place to manage potential Covid-19 situations. However, they do not change the waiver itself. If the waiver had not made absolute statements and had referenced the other documents, the situation might have been different. Related: ALAC Advice to the Board on the ICANN74 Travel Acknowledgement (2 May 2022) |
May 2, 2022 | Advice: ALAC Advice to the Board on the ICANN74 Travel Acknowledgement | ALAC submitted a request for the ICANN74 Travel Acknowledgement to be rewritten. They do not believe that the waiver takes into consideration important overarching principles, such as the trust relationship between ICANN and its important volunteer base and the bottom-up multi-stakeholder model, in which ICANN takes such great pride within the Internet community. Related: ALAC Response to ICANN Org Clarifying Questions on the ALAC Advice on the Travel Acknowledgement (31 May 2022) |
Apr 27, 2022 | ALAC identified specific problems that a policy development process would be expected to address, such as domain names registered for malicious activities and the effects of GDPR. As an outcome, ALAC identified a reduction in the number of domain names registered for malicious intent. In terms of next steps, ALAC recommends the GNSO Council's appointment of a small team consisting of experts of the ICANN Community to develop a catalog of activities to be targeted. | |
Mar 2, 2022 | Comment: ICANN Bylaws Amendments: ccNSO-Proposed Changes to Article 10 and Annex B | The proposed changes do not raise issues for end users, ALAC expressed its support. |
Feb 7, 2022 | Comment: ICANN Draft FY23-27 Operating and Financial Plan and Draft FY23 Operating Plan and Budget | The ALAC provided comments on the Draft FY23-27 Operating & Financial Plan and Draft FY23 Operating Plan and Budget regarding budget allocation, funding, and expenses. The ALAC also commented on policy development and advice improvements planned such as work related to the evolution of the ICANN Multistakeholder Model. ALAC stated it did not want to see the Holistic Review delayed. The Continuous Improvement program of all SOACs will be an ongoing effort, in parallel with the new Holistic Review. Budget allocation must be provided in FY23 and beyond, in order to ensure its completion before a second Holistic Review no more than 2.5 years after the initial implementation of recommendations from ATRT4. |
Jan 19, 2022 | ALAC has no concerns pertaining to the proposed ccNSO retirement process of ccTLDs. ALAC supports positions to ensure a transparent and smooth process that considers all stakeholders in its implementation. ALAC supports the approach, definition and process descriptions outlined in this proceeding and wishes the ccNSO to keep the two following items in mind: Assessing the impact of the retirement of a ccTLD on national interests and registrants. Having a clear review process for the two issues that could trigger a review mechanism. | |
Jan 13, 2022 | Comment: EPDP Phase 2A Policy Recommendations for ICANN Board Consideration | Alan Greenberg submitted a comment as ALAC representative to the PDP. Related: EPDP 2 (SSAD) ALAC Response to the Board's Understanding of the ALAC's Response to the Board's Clarifying Questions on the ALAC Advice (3 June 2022) |
Jan 12, 2022 | Advice: Response to Board Clarifying Questions: ALAC Advice on Subsequent Procedures | ALAC responded to eleven topics on which the ICANN Board requested clarification. Topics include |