Comment from ECLID on the Proposed Final Applicant Guidebook

[Davie Hutchison <leithclyde@xxxxxxxxxxxxxx>]

Please find below the comment from ECLID on the proposed Final Applicant
Guidebook. ECLID is the European Cultural and Linguistic Top Level Internet
Domain working group; it is a not-for-profit unincorporated association made
up of representatives of dotBZH, puntCAT, dotCYM, dotEUS, puntoGAL and
dotSCOT.



After many years of watching the ‘Internet community’ fight over issues that
will not, broadly, affect Cultural and Linguistic TLDs (clTLDs), such as
trademark issues and domain squatting, we were understandably excited to
hear a specific date mentioned for the start of the application process. As
before its apparent that this may be yet another false dawn. Every
indication we have seen leading up to, and now during, the Cartegena meeting
is that ICANN will once again bow to pressure from different lobby groups
and effectively punish the numerous communities worldwide that would benefit
from having their own TLD.



Almost everyone appears to agree that the clTLDs will be safe TLDs. puntCAT
has proven this and provides applicant clTLDs with a clear model. They have
no issues with trademarks, brand abuse, cyber squatting or Internet
stability and neither will the new clTLDs.



puntCAT and our clTLDs seek to foster defined, often small, cultural and
linguistic communities. The use of restrictive policies is the main
characteristic that guarantees the achievement of our main objective, and
the use of restrictive policies is mentioned in the proposed final version
of the AGB in its definition of community-based TLDs. It's now nearly 5
years since puntCAT's sunrise period and we are still waiting, by now
impatiently, for ICANN to allow other cultural and linguistic TLDs to be
properly represented on the Internet for the first time.



The constant delays to the timeline harm the small community applicants.
ICANN are now threatening to only process 500 applications a year, this
could delay a community TLD by another year or two.  If an application is
submitted in 2011 it's possible that the domains won't go on sale until 2014
– 9 years after puntCAT first went on to the root. Such a ridiculous
timeline potentially makes it even more difficult for community TLDs to find
funding and to survive.



ECLID is not the only one who shares this point of view. On September 23rd,
GAC pointed that there are "a number of relatively straightforward,
non-sensitive and uncontroversial gTLD proposals – including community-based
initiatives – which are being unduly delayed as a result of wider
operational and policy development issues that do not directly concern or
involve them".



"Applicants cannot prepare serious solutions with a timeline [that] shifts
with each ICANN meeting. Is this an effective outcome from a three-year
development cycle?".



This was denounced by the Step-by-Step initiative, which explained the
benefits of opening a fast-track window for uncontroversial candidates, at
the Sydney meeting in June 2009. Unfortunately, more than a year and a half
later, the potential for such an initiative lies unconsidered.



We ask that ICANN move forward at speed and with determination and prevent
further delay causing damage to the clTLDs and other community TLDs that
will enhance the richness and diversity of the Internet. Failing the courage
or resolve to do that, we ask ICANN to create a fast-track process for the
"safe" community TLDs which would be an excellent testing ground for the
process before opening it up to the non-community based TLDs.



We would also like to ask ICANN to consider the harm that waiting years for
an application to be processed could do to a not-for-profit community TLD
that are often managed by volunteers on a shoestring budget. These TLDs,
which will bring much more benefit to the Internet than the corporate TLDs,
should be processed first. We believe that clTLDs bring far more benefit
than cost to the wider Internet.  Business will go along as usual for the
big corporations but we can't afford to wait.



www.eclid.eu