dotBZH Comments on the 2nd Draft Applicant Guidebook
COMMENTS ON THE 2ND DRAFT APPLICANT GUIDEBOOK
DOTBZH IS A PROPOSED GTLD, INTENDING TO PROVIDE THE BRETON CULTURAL AND
LINGUISTIC COMMUNITY A SPECIFIC NAME SPACE UNDER THE .BZH TOP LEVEL DOMAIN.
THE APPLICATION OF DOTBZH WILL BE POSTED BY THE FRENCH _ASSOCIATION
WWW.BZH, _A NON-FOR-PROFIT ORGANIZATION, INCORPORATED IN QUIMPER, FRANCE,
IN JULY 2008.
FIRST OF ALL, WE WOULD LIKE TO THANK ICANN AND ITS STAFF FOR THE
CONSIDERATION THEY WILL PAY TO NOT ONLY OUR BUT ALL CONTRIBUTIONS THAT
ICANN OPEN PROCESS LETS US MAKE.
I - RECOGNITION OF THE CULTURAL & LINGUISTIC TLDS
The phenomenal expansion of the Internet created a large community of 1,5
billion users worldwide. To further promote and enrich its use, Internet
has to be made more accessible for all communities, including through the
global name space. By introducing in 2006 the .cat, specific to the Catalan
community, working on introducing Internationalized Domain Names under a
fast track system, and encouraging international
representation within its
own organization, ICANN has demonstrated its understanding of the need for
diversity in the Internet. In order to continue this effort, we suggest
that ICANN takes in consideration the specific needs and constraints of new
Cultural and Linguistic based TLD applicants.
The aim of such TLD is to make the name space of Internet more accessible
to our communities and promote the diversity of contents online. The
example of .cat shows that such registry would operate a modest number of
domain names (35,000) compared to commercial gTLD or even well developed
ccTLD. Nonetheless, the .cat has demonstrated its economical viability and
added value to the name space, given the high percentage of use per domain.
CONSIDERING THE PUBLIC INTEREST OF CULTURAL & LINGUISTIC TLD, WE THEREFORE
SUGGEST THAT ICANN RECOGNIZES THIS SPECIFIC CATEGORY OF APPLICANTS WITHIN
THE COMMUNITY-BASED DESIGNATION.
A proposed changed to the Applicant Guidebook could be:
"[...]
1.2.2
Two Application Types: Open or Community-
Based Designation
1.2.2.1 Definitions
[] An applicant for a community-based gTLD is expected to:
1. Demonstrate an ongoing relationship with a defined community that
consists of a restricted population.
2. Have applied for a gTLD string strongly and specifically related to the
community named in the application.
3. Have proposed dedicated registration and use policies for registrants
in its proposed gTLD.
4. Have its application endorsed in writing by an established institution
representing the community it has named.
IF THE DEFINITION OF AN INTENDED COMMUNITY OF USERS IS BASED ON CULTURAL
">REFER TO AN EXISTING LANGUAGE, AS RECOGNIZED BY UNESCO, AS A CONSTITUTIVE
ELEMENT OF THE COMMUNITY.
*
DEMONSTRATE THE RELEVANCE OF THE STRING TO THE COMMUNITY.
*
HAVE A NON-FOR-PROFIT STRUCTURE AS THE AGREED OPERATOR OF THE REGISTRY.
[]
Glossary
Terms Applicable to this RFP and to the New gTLD Application Process
[]
A
CULTURAL ">II - APPLICATION FEES
"_[...] __Outreach, transparency, and broadly participatory processes on
an international basis are not inexpensive. It is vital for ICANN to
continue to refine its models for sustainable operation, taking into
account the economics of the various actors in the Internet arena that rely
on ICANN's operation, and fairly apportioning costs of ICANN operation to
appropriate sources of support. Not all of the beneficiaries of ICANN's
work derive the same level of revenue from the Internet (and some, none at
all). ICANN must take into this into account in devising mechanisms for
supporting its operation and should work to make transparent the need to
provide services to parties who may not be in a position to contribute
commensurate with cost. Adequate and stable funding for ICANN is necessary
if ICANN is to fulfill its charter. [...]"_
Vint Cerf, _Looking Towards the Future_, Legacy letter to ICANN, October
2007
We understand the overall cost of
setting up a new procedure of
application and the financial interests at stakes with the process, however
the application fee, as it is, remains a major hindrance for non-commercial
bids and threatens the feasibility of Cultural & Linguistic TLD
applications. The organizations applying for a clTLD are non-for-profit
organizations with limited resources. They do not necessarily have access
to the same level of funding as commercial bids.
The resources as well as the mission of public interest of the clTLD
applicants should be taken into account by ICANN and therefore, THE
APPLICATION FEE SHOULD BE REDUCED TO USD50,000 FOR CLTLD. ICANN COULD DO SO
BY:
*
setting up a fast track for clTLD application
or
*
refunding part of the application fee once proved the Cultural and
Linguistic nature of the TLD
A PROPOSED CHANGED TO THE APPLICANT GUIDEBOOK COULD BE:
"1.5 Fees and Payments
This section describes the fees to be paid by the applicant. Payment
instructions are also
included here.
1.5.1 Description of Fees
The following fees are required from all applicants:
* TAS User Registration Fee - USD 100. This fee enables a user to enter
the online application system. This fee is nonrefundable.
* gTLD Evaluation Fee - gTLD Evaluation Fee - USD 185,000. ICANN will not
begin its evaluation of an application unless it has received the gTLD
evaluation fee by the due date. Refer to subsection 1.5.4. The gTLD
evaluation fee is set to recover costs associated with the new gTLD
program. The fee is set to ensure that the program is fully funded, and
doesn't take resources from other ICANN funding sources, including generic
registries and registrars, ccTLD contributions and RIR contributions.
[]
NOTE ON CLTLD APPLICANTS -
THE APPLICANTS FOR A CLTLD WILL BE ELIGIBLE FOR A USD 135,000 REBATE ON
THE APPLICATION FEE IF THE PURPOSE OF SERVING A CULTURAL AND LINGUISTIC
COMMUNITY IS CONFIRMED DURING ICANN EVALUATION.
Applicants may be required to pay
additional fees in certain cases where
specialized process steps are applicable. Those possible additional fees
include: [...]"
III - TIME LINE
Like all Cultural ">As far dotBZH is concerned, our limited resources will
not allow us to keep up with the ICANN pace, if the application period is
constantly postponed. If the financial aspect has been mentioned
previously, the critical matter derived from the unpredictable application
calendar is that our credibility is at stake with our local supports. This
credibility was already compromised, as ICANN in June 2008 in Paris,
announced the opening of a new round of application. Under the impression
that these future applications would be "open to anyone" and seemed easily
accessible, many external observers largely misunderstood ICANN message.
The absence of a reliable time line puts our TLD project at risk, in
regards to our accountability towards local supports, local authorities
most especially, as well as our ability to match the
high expectation from
our community.
WE WOULD URGE ICANN TO CONFIRM DECEMBER 2009 AS THE OPENING DATE OF THE
APPLICATION PERIOD FOR THE NEW GTLD.
Please find attached herewith our comment in pdf format.
Matthieu Crdou
Charg de mission
Tl: 02 98 10 00 30
Mob: 06 25 19 13 87
--
Association www.bzh
www.pointbzh.com
Un domaine Internet pour la culture et les langues bretonnes
Un astenn Kenrouedad evit ar vreizhadelezh
An Internet domain for the Breton culture and languages
Attachment:
[pikbzh]ICANN Comments.pdf |