ICC informal preliminary comments on the draft report of the Security, Stability and Resiliency (SSR) of the DNS Review Team

  • 11 November 2016

ICC welcomes the comprehensive draft report of the SSR Review Team which reflects critical analysis of the issues and scope of ICANN’s functions regarding the security, stability and resiliency of the DNS.

The International Chamber of Commerce (ICC)’s Commission on the Digital Economy and its Task Force on Internet and Telecommunications are pleased to provide this input on the draft report of the SSR Review Team.

This review under the Affirmation of Commitments (AoC) is particularly important. ICC members include companies and associations from across sectors and geographies, and ICC is a member of the ICANN Generic Name Supporting Organization (GNSO) Commercial and Business Users Constituency. The technical coordination of the Internet is of critical importance to all of our members particularly given the amount of their business that is conducted over it.

We welcome the opportunity to comment on this important draft report, and would like to reiterate that it is a challenge for organizations like ICC to complete our required consensus building process to develop comments when the comment periods are short; hence these are informal preliminary comments. We would greatly appreciate consideration of a longer comment period to ensure substantive input on ICANN work items. ICC previously has recommended that ICANN establish a standard consultation time frame, with a minimum of 30 days for an initial round of comments. Particularly for an association with representatives from multiple countries and industries, such a time frame would better allow for the preparation of detailed consensus comments from the ICC membership.