Whereas, on 18 September 2020, the Security and Stability Advisory Committee (SSAC) published SAC113: SSAC Advisory on Private-Use TLDs (SAC113), recommending that the ICANN Board ensure a string is identified and reserved at the top level of the Domain Name System (DNS) for private use, and that this particular string must never be delegated.
Whereas, the Board Technical Committee and ICANN organization have evaluated the feasibility of the SSAC's advice in SAC113 and developed a proposed approach for implementing the advice.
Whereas, on 20 October 2020, Göran Marby, President and Chief Executive Officer of ICANN org wrote Alissa Cooper, Chair, Internet Engineering Task Force (IETF) and Mirja Kühlewind, Chair, Internet Architecture Board (IAB) requesting further discussion on the recommendation of SAC113.
Whereas, on 12 November, 2020 Alissa Cooper on behalf of the Internet Engineering Steering Group and Mirja Kühlewind on behalf of the IAB responded.
Whereas, on 22 September 2022, the Board passed resolution 2022.09.22.08 directing ICANN org to conduct a Public Comment proceeding on a proposed procedure to identify and reserve a string for private use in accordance with the recommendation contained in SAC113.
Whereas, the Board has considered the letter received from the Internet Architecture Board, the comments received during the public comment proceeding, the additional input the SSAC provided in SAC2023-05, ICANN org's response to SAC2023-05, and the implementation recommendations from the Board Technical Committee and ICANN org relating to this advice.
Whereas, the Board resolved (2023.09.10.09) to direct the "Interim President and CEO, or her designee(s), to assess SAC113 candidate strings using the assessment criteria IANA has developed. This work is expected to involve the IANA functions that ICANN operates. After IANA has selected a string, the Board directs the Interim President and CEO, or her designee(s), to conduct a Public Comment proceeding to gather feedback on whether the string proposed by IANA meets the criteria defined in SAC113 Section 4.1. The Interim President and CEO, or her designee(s) shall then prepare and submit a report on the public comments received during this proceeding to assist the Board in determining whether to permanently reserve the string or not."
Whereas, the Board has considered the comments received during the second public comment proceeding on the proposed string for reservation .INTERNAL.
Resolved (2024.07.29.06), the Board reserves .INTERNAL from delegation in the DNS root zone permanently to provide for its use in private-use applications. The Board recommends that efforts be undertaken to raise awareness of its reservation for this purpose through the organization's technical outreach.
Rationale for Resolution 2024.07.29.06
Why is the Board addressing the issue now?
In resolution 2022.09.22.08, the Board approved a four-step process to implement the recommendation contained in SAC113.
The four proposed steps were:
- Conduct a Public Comment proceeding on the proposed approach in steps 2, 3 and 4;
- Instruct IANA to choose the string using the criteria described in SAC113;
- Conduct a Public Comment proceeding on the proposed string chosen by IANA in step 2; and
- Pass a Board resolution to reserve the proposed string.
ICANN org completed the Public Comment of the first step and published a report on its outcome. The Board then instructed ICANN org to choose a string using the criteria described in SAC113. IANA chose the string .INTERNAL. ICANN org then completed a second Public Comment on the chosen string and published a report on its outcome.
What is the proposal being considered?
The Board is considering whether to reserve .INTERNAL from insertion in the DNS root zone permanently. Applicants of the next and subsequent gTLD application rounds will not be able to apply for the .INTERNAL top-level domain.
Which stakeholders or others were consulted?
SAC113 discusses many of the efforts, both ongoing and abandoned, in the Internet Engineering Task Force (IETF) to try and resolve this issue. Since the publication of SAC113 the ICANN Board and the Internet Architecture Board (IAB) have exchanged correspondence about SAC113, briefly summarized below.
In the first correspondence from the ICANN Board to the IETF/IAB Chairs, the Board asked for clarification on what the definition of a 'technical use' was for domain names. Since the Memorandum of Understanding (MoU) between ICANN and the IETF considers 'assignments of domain names for technical uses' something the ICANN Board cannot delegate, assign, or instruct IANA to reserve unilaterally.
In its response, the IAB/IETF states:
We understand SAC113 to be a proposal for the ICANN [B]oard to allocate an ICANN Reserved Name, and we believe that it being reserved by ICANN would necessarily require that the chosen string also be removed from consideration for any technical use specified by the IETF. In keeping with our commitment to a single, global namespace (RFC 2826), such a reservation would ensure that the IETF would not consider any special-use name with the same string. Procedurally, if the ICANN board chooses to reserve a string following the advice of SAC113, we would expect the string to be reserved within the IANA-managed reserved domain registry rather than the special-use domain names registry.
The IAB/IETF did not voice any objection to the ICANN Board permanently reserving a top-level string.
During the first Public Comment Proceeding on the Proposed Procedure for Selecting a Top-Level Domain String for Private Use, ICANN received comments from the following groups.
- Business Constituency (BC)
- Governmental Advisory Committee (GAC)
- Intellectual Property Constituency (IPC)
- Network Information Centre for United Kingdom of Great Britain and Northern Ireland (UKGBNI)
- Registries Stakeholder Group (RySG)
- Security and Stability Advisory Committee (SSAC)
Two individuals also provided feedback in their individual capacities.
During the second Public Comment Proceeding ICANN received comments from the following groups.
- At-Large Advisory Committee (ALAC)
- Amazon.com, Inc.
- Business Constituency (BC)
- I Love Domains - United States o' America (ILDUSA)
- The IO Foundation (IO)
- Registries Stakeholder Group (RySG)
- Security and Stability Advisory Committee (SSAC)
24 individuals also provided feedback in their individual capacities.
What concerns or issues were raised by the community?
Community members have noted that, even if a top-level string is reserved for technical use, there is no way to compel equipment vendors, protocol designers, and others to use it. It is also not possible to determine the extent to which the chosen string will be used. It is therefore conceivable that implementing SAC113 could ultimately have no material effect on the DNS.
It is also likely not possible to choose a single string that will enjoy universal agreement as being the most appropriate string for this purpose. Different stakeholders and individuals may have different ideas of what the best string is for this purpose, and it will not be possible to identify a single string that will be acceptable to all stakeholders. This consequence is, however, distinct from the ability to choose a string that adheres to the criteria set forth in SAC113.
ICANN org initiated the first public comment proceeding on the proposed process and published a report on the public comment proceeding.
In response to the report of the first public comment proceeding the SSAC provided additional input via a correspondence, SSAC2023-05: SSAC Response to Public Comment Summary Report on Proposed Procedure for Selecting a Private Use TLD in which the SSAC commented:
The SSAC certainly acknowledges that much expertise exists within ICANN org to implement policy decisions. However, implementation plans, e.g., the work products of Implementation Review Teams, are routinely published for public comment before actual implementation. Therefore, it is disappointing that [the summary] response effectively dismisses the request to provide a more detailed selection process (implementation plan) and make that available for Public Comment before that process is undertaken.
ICANN org sent a response to SSAC2023-05 describing the procedure and noting that the Board still had to make a decision on whether or not to proceed with instructing IANA to select a string for reservation.
The Board then proceeded with instructing ICANN org to proceed with choosing a string for reservation with Board resolution 2023.09.10.09. IANA then proposed .INTERNAL and initiated a second public comment proceeding. Two themes were identified in the comments received that did not agree with the proposal.
The first was that .INTERNAL was too long. Six respondents to the Public Comment believed the selected string to be too long.
Additionally, one respondent believed that the string was not meaningful enough. This respondent viewed the analysis as insufficient to demonstrate the meaningfulness of the string, and concluded the assessment may need to be performed again.
What significant materials did the Board review?
The Board has reviewed SAC113, an Options Paper developed by ICANN org staff, correspondence between ICANN and the IAB, the MoU between ICANN and the IETF, the Public Comment Summary Report of the Proposed Procedure for Selecting a Top-Level Domain String for Private Use Public Comment, SSAC2023-05, ICANN org's response to SSAC2023-05, and the summary report on the second Public Comment Proceeding.
What factors did the Board find to be significant?
The Board recognizes that the problem highlighted in SAC113 is a legitimate and significant one that could, if not addressed, materially affect the DNS. Reserving .INTERNAL will not only close out SAC113, but also resolve a longstanding issue. Network administrators unable to use a name in the global DNS for their private, or internal, uses can now safely use .INTERNAL.
Are there positive or negative community impacts?
A positive impact from this Board resolution is to complete the process to provide a designated namespace for the private use of vendors and other users of the DNS. A negative impact is that there will be one fewer meaningful names available for delegation in the root zone.
Are there fiscal impacts or ramifications on ICANN (strategic plan, operating plan, budget); the community; and/or the public?
No additional fiscal impact is anticipated as a result of reserving .INTERNAL for private use.
Are there any security, stability or resiliency issues relating to the DNS?
The SSAC has identified many security, stability, and resiliency issues associated with the uncoordinated use of private-use names in SAC113. It is impossible to determine the extent to which reserving a string for private use will alleviate these issues. However, it will not introduce any new security, stability or resiliency issues. It will also not increase the severity of any known and existing security, stability, or resiliency issues.
Is this decision in the public interest and within ICANN's mission?
Reserving a string from delegation permanently is in the public interest for the reasons outlined in this resolution and rationale. It is also within the scope of ICANN's mission as described in the Bylaws. Specifically, Section 1.1 (a) (i) which states: "[ICANN] Coordinates the allocation and assignment of names in the root zone of the Domain Name System [..]".
In its letter to the Board, the IAB/IETF agreed that this reservation was within the scope of ICANN based on ICANN's MoU with the IETF.
During the first public comment proceeding there were no comments received stating that this reservation was not in the public interest or that it was not within ICANN's mission.
Is this either a defined policy process within ICANN's Supporting Organizations or ICANN's Organizational Administrative Function decision requiring public comment or not requiring public comment?
Reserving a string from delegation permanently is neither a defined policy process with ICANN's supporting organizations nor an ICANN administrative function. The Public Comment proceedings outlined in the four-step implementation plan are not required by the ICANN Bylaws, but are part of the proposed process for implementing SAC113. The purpose of this specific Board action is to finalize this process by reserving .INTERNAL permanently, thereby preventing applicants of the next and subsequent gTLD application rounds from applying for it.