In a comment filed with ICANN on the Name Collision Report of Interisle, the New gTLD Applicant Group (NTAG) signed by Tim Switzer, laid out a pretty compelling argument for why ICANN should not delay the roll out 279 new gTLD’s that fell within the “unknown risk category in the Interisle report.
“With such a long history of productive discussions, it is dismaying to see a great deal of uncertainty about the New gTLD program being introduced at such a late point in the process.”
While agreeing that the two strings listed as a “high risk” in the Interisle report (.Corp & .Home) should be delayed while further studies are conducted, NTAG citing a VerisignLabs.com technical reported entitled “New gTLD Security, Stability, Resiliency Update: Exploratory Consumer Impact Analysis” “pointed out that the Previous Expansions of the TLD’s to the root did not cause any issues that the Interisle report tried to identify.
The Verisign report which used data from January 2006 prior to the launch of several active TLDs, found that .xxx received more queries before delegation than any other new TLD.
“Despite having more queries than of all of the TLDs currently under consideration in the “Uncategorized Risk” category, .xxx was delegated in 2011.”
“This TLD launched without incident, and no public complaints or technical issues have been identified since.”
“In addition, most of the other TLDs listed in Table 1 of the Verisign report, including .asia, .kp, .ax, .um and .cw, also demonstrated much higher numbers of NXDOMAIN responses than all 279 of the “uncategorized” strings, and again all were delegated with no noticeable impact.”
“In fact, the least “dangerous” current gTLD on the chart, .sx, had 331 queries per million in 2006. This is a higher density of NXDOMAIN queries than all but five proposed new TLDs.”
“Again, .sx was launched successfully in 2012 with of the problems predicted in these reports.”
These successful delegations alone demonstrate that there is no need to delay any more than the two most risky strings.”
I think that is very good point, if you look at the Verisign study .XXX had a PPM of 4018. by comparison the two strings identified as “High Risk” in the Interisle report .Home has a PPM of 27,885 and .Corp had a PPM of 4085 which were the only two strings that had any PPM score close to .XXX.
.XXX did launch back in 2011 and As NTAG said “no incident, and no public complaints or technical issues have been identified since.”
NTAG then went on to say “There is no reason for ICANN to delay the 279 “uncategorized” names any further, and reasonable protections can be put in place while the existing new TLD calendar is executed. None of these strings pose any more risk than .xxx, .asia and other currently operating TLDs.”
“We believe that the Board can take the following four steps to accelerate the mitigation process without bringing this important expansion of the Internet’s namespace to a halt.
1) Proceed with IDNs
IDNs were not listed in Interisle report, confirming no name collision issues were seen in either certificates or DNS queries
We suggest ICANN to continue to proceed to delegation for IDNs without requiring 120day waiting period or 30day mitigation process while staff, applicants and the Board work on deciding risk assessment and mitigation for ASCII TLDs. <
2) Proceed with the “Unknown Risk” Strings using the “Low Risk” Mitigations
We believe strongly that the expansion of the namespace will improve the safety, stability and performance of the Internet. We recognize that a small number of applied for names may possibly pose a risk to current operations, but we believe very strongly that there is no quantitative basis for holding back strings that pose less measurable threat than almost all existing TLDs today.
This is why we urge the board to proceed with the applications classified as “Unknown Risk” using the mitigations recommended by staff for “Low Risk” strings. We believe the 80% of strings classified as “Low Risk” should proceed immediately with no additional mitigations.
3) Accelerate Handling of the Certificate Collision Issue
NTAG members have discussed the handling of the CA collision issue with prominent members of the Certificate Authority industry and believe that a much more efficient solution exists than the current agreement with the CA/Browser Forum.
We believe that the Board can write to the CA/B Forum today and inform them that all but a handful of new TLDs are very likely to be delegated in the next two years and, for the benefit of their customers, the 120 day revocation process should begin today.””
