Comment on Retiring Country Code Top-Level Domains

[Alan Levin <alan@xxxxxxxxxxxxxxxxxxx>]

Hi,

I am writing in my personal capacity only and please accept my  
comments as my personal opinion and not that of any of the  
organisations that I work for.

My involvement with cctld's has spanned over ten years and has been  
from an end user perspective as well as researcher, reseller,  
advisor, educator and member of the governing boards of two tld's. I  
have some formal training on the DNS as well as thousands of  
interactions and transactions with dozens of registries, registrars  
and registrants. I am also a founding member of the CCNSO IANA  
working group.  Through my involvement in these areas I am well aware  
of the issues presented in the discussion paper.

I understand that registrants may lose their domain names in this  
process and I am of the opinion that as long as they are allowed to  
comment, registrants are prepared for any outcome (else they will  
have to become prepared very quickly). We cannot foresee all possible  
risks, but we need to obtain more experience in this before we can  
best understand.

With respect to your guiding questions:
>    1. Should IANA adhere to the ISO-3166 standard and remove top- 
> level domains from the DNS root that become transitionally reserved  
> (i.e. retired)?

Yes, subject to:

>    2. If so, by what process should this be conducted?

ICANN Board ratification. The ICANN board should call for public  
comment for each of retiring cctld - on a case by case basis - before  
making the final decision.

>    3. What implementation timeframes for removal should be specified?

Once the ICANN board have ratified the decision, it should go into  
the IANA ticketing queue as low or medium priority. When the IANA  
reach that ticket, the 'removal' action should be effected.

>    4. If removal is test-based, what specific milestones should  
> signify removal from the root zone?

Closure of the IANA ticket (i.e. when the IANA decides).

>    5. What pre-emptive right, if any, should existing operators  
> have toward a new code that covers an area previously serviced (in  
> whole, or in part) by another code?

Dependent on the ICANN board decision.

>    6. In the event there is more than one code for a particular  
> country available for its use (e.g. GB and UK), what policy should  
> govern their status?

This should be handled on a case by case basis. No set policy should  
be adopted until more examples have been dealt with. i.e. it should  
be handled the same as any retiring cctld, where the ICANN board  
calls for public comment and subsequently makes their final decision.

Warm regards,

Alan


---------------------------------------------
Alan Levin
Tel: +27 21 409-7997