Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

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Name: Ephraim Percy Kenyanito
Date: 18 Nov 2022
Affiliation: Cross-Community Working Party on ICANN and Human Rights (CCWP-HR)
Summary of Submission

We welcome ICANN’s decision to release the document in its entirety, in line with Workstream 2 Recommendations on ICANN Transparency. 

We note that the Proposed Amendments to the SLA for the IANA Numbering Services are aimed at incorporating obligations for the administration of reverse DNS resolution services, as part of the contractual obligation under the 2016 IANA stewardship transition to enable ICANN and the five Regional Internet Registries (“RIRs”) to continuously coordinate the number resource administrative function. 

We particularly note that the amendments include the obligation that “[t]he Operator’s DNS server must run software which correctly implements all the applicable DNS IETF RFCs.”

In addressing this proposed amendment, we would like to bring the attention of ICANN and RIRs to IETF RFC 8280, Research into Human Rights Protocol Considerations. In particular, RFC 8280 sets out guidelines for human rights considerations whereby designers, implementers, and users of Internet protocols are aware of human rights-related design choices. Similarly, IETF RFC 6973 sets out guidelines for privacy considerations and provides a framework for ensuring that designers, implementers, and users of Internet protocols are aware of privacy-related design choices. 

Human rights considerations at the DNS level are critical, as the rights of Internet users and registrants to privacy, freedom of expression, and freedom of association may be directly threatened by actions such as domain suspensions or blocking, or indirectly threatened through the exposure of their personal information, including when registering a website. 

As the proposed amendments are currently drafted, RFCs that may not be classified as strictly “DNS IETF RFCs” may nevertheless be applicable to ensuring robust DNS server operations. In particular, RFCs 8280 and 6973 are essential to ensuring compliance with Section 27.2 of the ICANN Bylaws (Human Rights Bylaw) and other ICANN Bylaws with an imp