Comments on .aero Renewal Proposal

[Ross Rader <ross@xxxxxxxxxx>]

This renewal proposal requests modification of the registry agreement to 
allow the registry to develop alternative distribution channels outside 
of the regular registrar accreditation policy and to allow SITA to deal 
directly with the registrants.

This is a puzzling request in that the registry operator is free to 
undertake the development of any distribution channels it wishes to 
within the bounds of the current registrar accreditation policy. 
Specialized distribution is necessary to deliver different services to 
different market segments - but this does not mean that registrar 
accreditation policies should be waived. The original registrar 
accreditation policy was implemented to ensure not only a competitive 
environment as the registry operator points out, but also to ensure a 
stable, predictable and secure environment that met the requirements set 
out by the Internet community, the White Paper and ICANN's policy 
development process. SITA has incorrectly assessed accredited registrars 
as a homogeneous distribution channel leading to an assumption that the 
current service failures are related to the distribution channel being 
used. Given that any organization that qualifies may become accredited 
to act as a registrar, it also stands to reason that organizations with 
the skills SITA views as necessary for distribution of .aero 
registrations could become accredited.

SITA should be encouraged to develop a specialized distribution channel 
- one that will presumably see new specialized registrars become 
accredited in order that they meet the technical, financial and 
operational requirements set forth by ICANN. but ICANN's implementation 
of the Registrar Accreditation policy in this sponsored TLD agreement 
should not be changed.

Regarding SITA's request to deal with the public directly, this request 
should be granted, provided that SITA create and implement plans to 
ensure that the obvious internal conflicts of interest are avoided and 
that the registry can provide equal access to all registrars, including 
its own, without favoring any specific one (especially its own).

On behalf of Tucows Inc.,

Ross Rader