Compulsory DNSSEC and 99.9% availability of the Registration Data Publication Service (RDPS) and the EPP service are uneconomical technical requirements
Dear ICANN staff,thank you for your efforts in bringing this process forward and finding a well working balance between the many and often contradicting requirements of the community.
From a technical standpoint, I have noticed two severe technical modifications in version 3 of the draft applicant guide book and the draft new gTLD agreement, which seem to unnecessarily limit the competition on the TLD and registry market.
DNSSEC:As stated in version two of the guide book, DNSSEC should be an optional feature of a registry. Offering DNSSEC might be a unique and important selling proposition for one TLD and its domains. For other TLDs it might be an unnecessary driver of costs. It should be left within the general responsibility of a TLD-owner whether and when this feature is introduced and thus fosters the competition amongst TLDs.
Availability of RDPS and EPP service:The tightened requirements of 99.9% availability for RDPS and EPP services including all planned outages seem to go far beyond the practical requirements of some potential new gTLDs. I propose that the requirements are reduced to the 99% value as stated in version two of the draft new gTLD agreement.
99.9% availability of a multi level technical infrastructure including planned outages require complex system architectures and operational processes which significantly increase the infrastructural costs. Some new TLDs might want a nearly 100% availability of the RDPS and the EPP system, require it from their technical operators and pay the price. For others, the actual requirements might impose unnecessary costs. Reducing the minimum requirements to 99% will leave responsibility with the TLD-owner and thus again foster the competition amongst TLDs and registry service providers.
Sincerely Stefan Legner SLcon IT & Management Consulting Germany