Re: [dow3tf] Best Practices Ballot

["Ross Wm. Rader" <ross@xxxxxxxxxx>]

On 5/26/2004 4:22 PM Brian Darville noted that:


> Please vote on each section of this document.  Please indicate your vote in this document and email it to the Task Force and to bdarville@xxxxxxxxx by 3:00 pm EST tomorrow, Thursday, May 27, 2004.

Brian - thank you for taking this input into consideration, despite the 
manner in which I presented it. My apologies to the task force and our 
chair.

To the matter at hand, I have taken counsel from members of the 
Registrar Constituency and other GNSO participants and must respectfully 
vote "no" on all counts, with qualification, on the proposals contained 
in this draft.

Those qualifications being;

1. There are a limited number of highly onerous requirements that cause 
substantial portions of the document to become unacceptable to registrar 
interests. For instance, the requirement to admit liability and submit 
to a managed remediation plan in the event that a registrar is 
non-compliant with some or all of their Whois related obligations is an 
unworkable aspect of this document. However, many of the subordinate 
terms would be acceptable to the members of the Registrar constituency 
if they were not associated with the liability that comes with the 
declarations.

2. The proposal mixes active and passive verification techniques with 
seeming disregard for the actual quality of the end result. It is the 
registrar position that passive verification coupled with mandatory 
participation in the Whois Data Problem Reporting System will create a 
substantial increase in the quality of the data contained in the Whois 
database without undue impact on registrants and registrars. Active 
verification at the time of registration, beyond simple data 
characteristic checking is an unproven and unexplored option that is 
likely to impose significant cost and burden on registrants and registrars.

3. The proposal does not adequately consider the true impact of existing 
programs nor does it consider potential improvements to these programs 
in an effort to achieve whois data accuracy. The proposal is silent on 
existing programs like the WDPRS despite very strong data that it is a 
viable option that we should seriously examine and potentially mandate 
as policy.

4. The proposal does not sufficiently consider the inputs of the SSAC 
and other historical GNSO proposals including the results of the prior 
Whois Task Force. ICANN and the GNSO have developed a substantial number 
of recommendations and considerations that were not considered for 
inclusion in this report. The sum of many of these is likely to have a 
drastic impact on increasing the Whois data quality.

Overall, there are a number of elements of this proposal that the 
registrar constituency could support, but given the unintended - but 
likely - consequences, we must formally oppose this particular version.

I sincerely appreciate the investment that has been made in this 
document by the members of this task force and urge everyone to continue 
moving forward with this difficult, but important process.


--
Regards,


                       -rwr








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