Paul Wouters has entered the following ballot position for
draft-ietf-regext-epp-delete-bcp-09: No Objection
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COMMENT:
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Thanks for the clear description of the problem and the operational and
security issues involved. I think this is good work to get a BCP for to reduce
harm.

Some of my comments I left below, I felt on the border of a DISCUSS or COMMENT.
I chose to leave it as COMMENTS.

        5.1.3.4. Renaming to Sacrificial Name Server

This description does not seem to match the idea of "sacrificial" name server.
It is more a dedicated nameserver maintained by the client/registrar. Maybe
"Last Resort Name Server" is a better name?

        The name server MAY provide any valid response.

This one is tricky. Of the domain using the host object has other still valid
nameservers, it would be better to ServFail. If there are no more other valid
nameservers, resolving everything to a dedicated IP running a webserver hosting
a message "no valid nameservers for this domain" could be useful. But such a
message is harmful if the domain has other still functional nameservers.

        5.1.4.2.1.2. Practice Detriments

        These TLDs are reserved for experimentation or testing. Their
        use is confusing and does not signal the client's intent. Their
        use may be prevented by policy.

The first two sentences are not correct when ".invalid" is used. The last
sentence seems a weak argument. I think ".invalid" would make a good solution
here, and I would turn around the last sentence and make this document state
that use of .invalid SHOULD NOT be prevented by policy.

        5.1.4.3. Renaming to a Special-Use Domain

Only after reading 5.1.4.3 do I realise that 5.1.4.2 meant only "invalid." as
FQDN when it said ".invalid" and not SLDs inside .invalid. That is not obvious
to the reader and I think should be explicitly stated. (Or 5.1.4.3 could be
removed with some text moved into 5.1.4.4?)

I think adding another name string Special Use Domains should be avoided. There
are attempts to stop allowing Special-Use domains entirely, and taking up a
"nice name" also takes that name away for real registration in the future.

One could instead use something like invalid.arpa or broken-ns.arpa instead?
(Oh, I see that is what 5.1.4.4 is doing)

I feel Section 5.2 has little to do with IETF and protocols, and is much better
handled in other venues? Like ccTLD orgs and/or ICANN ? It is harmless here,
but any BCP guidance in this section is not protocol guidance but guidance for
the RRR-model.

I strongly dislike the term "sacrificial.invalid". Registrants will not have an
intuitive grasp for what this means. For example "deleted-ns.invalid" would
convey a much clearer signal of what has happened. Furthermore, "sacrificing"
implies that this situation is about to change, which is almost never what
is described here. It is a lasting change until the registrant or registrar
fixes the domain delegation.

I am not sure if the document has properly taken into account whether queries
in the "sacrifcial name" in the various solutions would be handled and eaten
by the Recursive DNS or be forwarded to the root nameservers. This might depend
on the name used as well. But for example, my unbound nameserver (and Quad9)
seem to synthesis the .invalid response, thus suppressing queries to the root,
while Google DNS and Cloudflare seem to return a SOA of the root zone, implying
it might have actually sent the query to the root. This might cause quite some
load if a popular domain were to end up in such a bad situation.



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