PuntoGAL (dotGAL) new comments on the new TLD Program and the Applicant Guidebook

[Manuel Vilas <manuel.vilas@xxxxxxxxxxxx>]

PuntoGAL is a non-profit association committed to promoting DotGAL
(PuntoGAL), an Internet Domain for Galician culture and language which will
represent over 4 million Galicians living all over the world.

PuntoGAL has already gained the support of more than one hundred
associations and more than 12.000 internet users. As soon as ICANN launched
the ngTLDs program, the association also gained the support from linguistic,
local, regional and national authorities.

Logically, the long delay of the process harms the Galician speaking
community's opinion about the process and ICANN's role and therefore puts at
risk the candidature.

The same problem applies to other linguistic and cultural non-profit
organizations. "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?" stated the Step-by-Step initiative more than
18 months ago.

Although PuntoGAL thanks ICANN's staff for the hard work put into developing
this Proposed Final Applicant Guidebook (AGB), it also points that further
delays, as the resulted from Cartagena, difficult ICANN's objective to
promote a more multicultural and multilingüsitic Internet.

In consequence, PuntoGAL would like to suggest an alternative that could
prove to the Internet community that the process has not come to a halt
indefinitely.

The Proposed Final AGB clearly states the rules by which community based
gTLDs are to be identified. These rules have not been significantly
criticized.

According to the "1.2.3 Community-Based Designation” criteria, these
category of candidates must “demonstrate an ongoing relationship with a
clearly delineated community”, have to “applied for a gTLD string strongly
and specifically related to the community named in the application”,
“proposed dedicated registration and use policies for registrants in its
proposed gTLD, including appropriate security verification procedures,
commensurate with the community-based purpose it has named” and, moreover,
“have its application endorsed in writing by one or more established
institutions representing the community its has named”. In addition, “4.2.2.
Community Priority Evaluation” deals in detail with string priority.

If you apply this criteria to cultural and linguistic candidates, you will
find that most of the concerns about the process pointed out in the GAC
Communiqué and other agents' comments simply do not affect this category of
proposals. This was clearly seen in the lack of conflict during the launch
of dotCAT, the domain for Catalonian language and culture, and its current
success.

To put it in the GAC's own words, on September 23rd: "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".

Moreover, community based cultural and linguistic domains will bring the DNS
closer to reflecting one of the main changes on the Internet in recent
years, namely the increasing cultural and linguistic diversity of the Net.

In conclusion, if a full consensus about the AGB is not reached, PuntoGAL
would ask ICANN to open a window for these "non-sensitive and
uncontroversial gTLD proposals" previous to the launch of the full process.
This early window will be a perfect test rule for the current rules. We
would like to make clear that PuntoGAL is not asking for a specific set of
rules to examine cultural and linguistic proposals. However, these community
based gTLDs would be an excellent tool to test the AGB before opening the
full process. No one would might be harmed by this early window, and all the
candidates, and the ICANN itself, will be benefit from it.