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