[NCUC Public Comment] Thick and Thin Whois Preliminary issues report -- draft comment

[nhklein]

+1

Norbert

=

On 12/27/2011 09:49 PM, Milton L Mueller wrote:
> Wendy,
> Great statement, I support it. I see  no reason why it couldn't be considered a NCSG comment as long as there are no objections forthcoming.
> And it was drafted by our SG's council rep who got the most votes!
>
> --MM
>
>> -----Original Message-----
>> ----draft comment----
>> [NCSG] offers this comment on the Preliminary Issue Report on 'Thick' Whois.
>>
>> As an initial matter, we question the impetus for this policy-making.
>> It is not clear that changing the thickness of WHOIS responds to the
>> IRTP working groups' concerns about secure data exchange in a transfer,
>> as neither the security properties nor alternatives are described in any
>> detail.
>>
>> The items in the Applicant Guidebook, in particular the requirement that
>> all new gTLD applicants provide thick WHOIS, do not reflect a GNSO or
>> community consensus.  It would therefore reverse the policy-making
>> process to assert consistency with new gTLDs as a rationale for creating
>> a policy that required existing registries to change their WHOIS model.
>> The issue report correctly notes that no policy currently exists as to
>> WHOIS model. We do not believe this PDP is the time or way to make such
>> policy.
>>
>> Further we question the timing and sequence of this proposed PDP.  A
>> drafting team is currently developing a survey of WHOIS technical
>> requirements, to gauge community needs from the WHOIS system.  Policy
>> requiring thick WHOIS appears to offer a solution without before the
>> problem is defined -- and so risks "solving" the wrong problem, while in
>> the process reducing flexibility to solve actual problems that the
>> community identifies.  We also have ongoing WHOIS studies. As the GNSO
>> Council frequently hears about the overload on staff resources, and
>> community members themselves face numerous competing demands on
>> their
>> time, we believe these resources could be better optimized by rejecting
>> this PDP or postponing it until the prior WHOIS work gave definite
>> objectives that required changes to the WHOIS model such as a thick WHOIS.
>>
>> Within the report itself, we would like to see more consideration of
>> alternative models, such as standards that could streamline the
>> distributed database of thin WHOIS, or a centralized database.  Many of
>> the format and accessibility concerns, for example, would appear to be
>> better served by agreement on a standardized format for WHOIS data
>> responses than by requirements on where the data must be kept. A new
>> policy meant to address these concerns should look at their root causes,
>> not
>>
>>
>> As this preliminary issue report was completed before the adoption of
>> the new PDP process, it does not contain the impact analysis recommended
>> there. NCSG has particular interest in the impact on privacy rights.
>> Moving all data to the registry could facilitate invasion of privacy and
>> decrease the jurisdictional control registrants have through their
>> choice of registrar.
>>
>> ----end draft comment----
>>


-- 
A while ago, I started a new blog:

...thinking it over... after 21 years in Cambodia
http://www.thinking21.org/

continuing to share reports and comments from Cambodia,
and this is my last posting:

Some clarifications – Christmas
http://www.thinking21.org/?p=624


Norbert Klein
nhklein at gmx.net
Phnom Penh / Cambodia