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A comment on the continuity instrument requirement as a tool to diminish diversity

  • To: 5gtld-guide@xxxxxxxxx
  • Subject: A comment on the continuity instrument requirement as a tool to diminish diversity
  • From: Eric Brunner-Williams <ebw@xxxxxxxxxxxxxxxxxxxx>
  • Date: Thu, 09 Dec 2010 17:16:07 -0500

I would like to point out that for registry services technical providers, the incremental cost of providing continuity operations -- the monthly reports to ICANN that contain only nominal editorial changes, the service of renewing a few domains per day, the service of servicing a few DRP requests per month, the service of publishing a nearly unchanged zonefile, the service of publishing nearly unchanged whois data, ... is wicked close to ZERO.

The net of the three year operational continuity funding instrument requirement is to provide existing registry services technical providers -- Verisign-GRS, Afilias, NeuStar, CORE, AusReg, ... with an incentive for applicants to select an existing registry services technical provider over building out their own technical infrastructure -- an incentive in the middle of the six-figure range denominated in US dollars, or two to four multiples of the ICANN application fee.

Applicants who use the services offered by existing registry services technical providers, including the continuity operations guarantee, risk paying more in revenue points and policy manipulation to their service providers than the true value -- and I repeat -- for multi-registry operators such as all of the existing gTLD registry back-end providers, and some ccTLD registry back-end providers, the true cost is wicked close to ZERO -- of continuity operations.

The DAG can, and should, instruct applicants that they may form risk pool cooperatives and invent something as non-novel as mutual insurance so that they too, without capture by an existing back-end services provider, write "guaranteed" in response to the continuity instrument question.

I'd like to see scores, even hundreds, of new facilities-based registry operators, as that independence, diversity of capacity, is the sina qua non of diversity of content. That isn't encouraged if the first cohort of applicants are forced, by very high fees and real uncertainties after years of delay, and an additional multiple of the application fee lost for several years to an interest-bearing account, unavailable for rainy-day draw-downs when the registry fails to meet its numbers for a quarter, or unforeseen non-recurring cost, to select being captive properties of existing facilities based registry operators -- their competitors.

This is a fixable error in the DAG, I hope it is fixed and not forced on applicants.

Eric Brunner-Williams
in a personal capacity

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