Comments on Introduction to New gTLDs Application Process, section 1.1.5, Subsequent Application Rounds
The footnote on page 1-13 makes mention of prior comments, ours included, on the need for either fixed dates for the subsequent application rounds, or the time offset between rounds, and restates a commitment to timely implementation of further application rounds. Because the DAG, versions 1 and 2, address the most adverse assumptions about applicant behavior, application quality and registry operations, its authors have adopted process formalism as a defense. We've suggested during the face-to-face meetings, and in prior public comment, that some subset of the applications we are aware of meet the "safe and sane" test of many of us who have been involved in registry applications and operations over the past decade, that despite our status as competitors, we can look at each other's applications and quickly triage them into "safe", "unsafe" and "takes more thought" baskets. The benefit to an approach to application initial intake management by those of us who have, and do this kind of thing professionally, is that we can find out if formalism really is required, and if so, if it is required for all applications equally, or if it is only helpful for problematic applications, whether the problem arises from the applicant being unfamiliar with the industry, or wicked familiar and clever by intent. We don't yet know if the process staff is in the process of thinking through will work, and as a process problem, we've no way to test it with real applications and determine whether the one-year goal is realistic, or could be made more, or less frequent. As any informed reader of the public comments and correspondence must be aware, there is no shortage of advocates for no further gTLD introductions, a position consistent with retaining the incumbent monopoly operator dominating the market, based upon the same, most adverse assumptions about applicant behavior, application quality and registry operations. We know there are applications for which these adverse assumptions are incorrect, and the correctness of staff's process model cannot be shown until application processing begins, and beginning with a manifestly safe set of applications will benefit the applicants, the advocates for no further gTLD introductions who will be able to distinguish between applications that do not harm their interests, and those that do, and develop better tools than mere obstruction and high theater, staff, which is on the spot to invent a process that has no real predecessor, failed or successful, to draw experience from, and the registrars and registrants of those manifestly safe set of applications. In sum, start soon and small and see if the wave of applications breaks as expected, triage, using the available time and experience of existing registry operators, set a schedule for iterations of the application process, and expend the formalism on the applications which really must be improved, junked, or approved but under significant oversight. I work for CORE, CORE will submit applications, so this interest in the outcome should be included in my comment. Eric Brunner-Williams |