The ICANN assessment categorized 2 of the TLDs as “high risk” and 1,000 as “low risk,” but also categorized 150 as having an “uncalculated risk” of collision. Neustar claims that the risk of collision for the “uncalculated” category is calculable. Further, having done the calculations, Neustar agrees with the ICANN classification of .home and .corp TLDs as “high risk,” but suggests adding only .mail into the category, while finding that all other proposed TLDs in the “uncalculated” category can be considered “low risk.”
“ICANN’s mitigation strategy rests entirely on the possibility of collision, not the consequences. As a result, ICANN’s plan would relegate many demonstrably low-risk TLDs to the nether world of ‘uncalculated risk’ and impose further unwarranted delay in the launch of those TLDs,” according to Neustar Deputy General Counsel Becky Burr. “Moreover, we disagree with the need for delay to conduct additional research in order to quantify the risk associated with introduction of the vast majority of proposed new TLDs. Rather, we believe that ICANN already has all the data and research necessary to calculate the risk and develop mitigation strategies that are carefully tailored to the specific risk associated with each TLD.”
Neustar’s comments are critical of the ICANN assessment methodology and the uncertainty resulting from it for so many TLDs. However, for the TLDs which ICANN considers as having calculable risk, Neustar’s “refined” analysis process delivers practically identical conclusions. The added “high risk” TLD .mail has a risk score of 2.17, while .home has a risk score of 62.99, and .corp is even higher, according to Neustar.
The harm of delaying the “uncalculated risk” TLDs and the related uncertainty is emphasized in Neustar’s comments. Neustar also objects to ICANN’s proposal to gather more information to analyze the delayed TLDs, saying the available information is sufficient to generate their improved results.
The Neustar report offers suggestions for mitigating the consequences of DNS collision, as well as taking those consequences into account to re-categorize the 150 “uncalculated risk” TLDs.