Hi All:
Thanks Garth for providing your input to ICANN.
I have used your response for additions and clarifiactions.
I hope this is acceptable to all.
GENERAL OBSERVATIONS:
Q1. Should IANA adhere to the ISO-3166 standard and remove top-level
domains from the DNS root that become transitionally reserved (i.e.
retired)?
Opinion: A ccTLD should represent a country or it's territories - and
be managed in accord with applicable local legislation. Codes which
cease to represent a country or territory should be phased out -
provided the IANA has included a "replacement" ccTLD in the root for
the effected registrants / communities.
I would like to expand on the above point.
I note that the system does not rely solely on ISO-316 was the case
of Palestine.
It could be argued that there are a number of inconsistencies in
defining what is a country.
If the system is based on one domain per country then there needs to
be a definition of what this means in practice.
If the case is one country = one domain then it could be argued that
China does not meet this model / eg Macau - Hong Kong.
If being a country = is recognition by the United Nations, then it
can be argued that the Tibet should equally have access to a country
code. It was originally excluded from international codings as its
culture ore 1949 was one of isolation (At that time there was one car
and it did not subscribe to the International Postal Union.)
There is also the example of .io ( Indian overseas territories) where
the local population were moved to the UK. Susequent court cases, in
the UK have decided that this action was illegal.
The question that this raises is how can there be an internet domain
code for .io when local people are not participating or represented,
a condition which is a necessity, as far as I understand, under the
current rules.
(The only population currently there comrises of US servicxemen and
UK support personnel.)
2. If so, by what process should this be conducted?
Opinion:
- Where applicable the IANA ( in consultation with the applicable
governments and local stake holders) should swiftly designate a
competent entity to manage new replacements "ccTLDs".
- The ccTLD manager of the TLD being retired should cease to allow
new registrations in the ccTLD being retired.
- The new "Sponsoring Organization" should be encouraged to work
with with the administrator of the ccTLD being retired existing to
ensure existing registrants are granted an opportunity to have their
existing domain "mapped" to the new ccTLD if applicable. (sunrise
for existing registrants)
- Domains in the ccTLD being retired should be allowed to lapse
naturally (provided the registration period is not excessive - 7+
years)
I agree to this position on th4e retirement of domains.
I would suggest that IANA use the opportunity with the oldest domain
being retired to work towards generating a set of processes and
procedures to guide all future activities of this type.
3. What implementation timeframes for removal should be specified?
Opinion:
- A maximum of 5-7 years.
- Existing names which are registered should be allowed to renewed -
if desirable for 5-7 years.
4. If removal is test-based, what specific milestones should signify
removal from the root zone?
Opinion:
- removal should be based first and foremost on the availability of
a suitable replacement ccTLD for existing registrants to migrate to.
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?
Opinion:
- Where the new ccTLD is run as a shared registry, consideration
should be given to allowing legacy operators as a minimum registrar
status in the new registry and where possible/desirable input in the
administration of the new ccTLD.
I agree
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?
- No Opinion.
From my researches it appears that the original model for the
organisaiton of the internet was based on a purely US model - com
net org etc.
The isue of the UK domain, I believe was made on request from a UK
university. This of course is incorrect as illustrated by all the
other international codes that apply to there..
OTHER CONSIDERATIONS:
Minimum performance for polices (AUP / DRS / PRIVACY&Whois) which
apply to a ccTLD being retired should be established and agreed
between the IANA and the admin of the ccTLD for the duration of the
"phase-out" period. The IANA should consider developing a generic set
of polices for a ccTLD which is no longer covered by any local legal
or public policy framework, it should at a minimum be subject to a
gTLD style DRS set of policies.
See comments above on IANA providing a model.
.TP SPECIFIC OBSERVATIONS / CASE STUDY:
The launch .TL and the phase out of .TP has followed the the
recomendations above.
- On launch of the .TL ccTLD Connect Ireland (the operator of .TP)
complied with a request from the Government of East Timor to cease
new .TP registrations and provided a copy of the existing .TP
database to the .TL administrator.
- The .TL administrator mapped all existing .TP domains to to the .TL
"version" - this was done free of charge.
,tp provided all the necessary data for the above activity to ensure
a smooth chageover and consistency for the internet community.
- Existing registrants and registrars were given a common interface
to update contact details / name sever details.
- Connect Ireland has adopted the .TL polices and made them
applicable to .TP domains.
- The number of active . TP domains is considerably less than that
which has been reported in the press.
I am unaware of any press announcements in the past 4 years with
regard to .tp
We have never, to my knowledge, issued any figures on this subject to
and the press and I assume that this figure has been reported
incorrectly by members of the media.
Current .TP Register statistics. (according to the CoCCA Registry -
it should be noted that the .TP zone is maintained by Connect Ireland
and the CoCCA Registry is used to generate the .TL zones and
the .TP/.TL Whois)
Domains 844 - Active
Expiring....
592 expire in 2007
229 expire in 2008
15 expire in 2009
The .TL Ministry of communications has requested Connect Ireland not
allow renewals and phase out the .TP domain as swiftly as possible.
Connect Ireland has advised that by the end of 2009 all .TP
registrations will have lapsed and the .TP ccTLD could be retired and
removed from the zone. The .TP ccTLD could be retired as early as the
end of 2008 though consultation with the few registrants remaining at
that time. It should be noted that most .TP registrations are
defensive registrations and not in "use" - a handful of .TP domains
are in active use in Timor Leste (including the monopoly local ISP /
phone company and a few NGO's and government departments ) migrating
away from these domains requires some time as the cut over impacts
many local Timor Leste users.
I would add that many, if not all smaller cctlds are mainly comprised
of "defensive registrations" This can be shown as a natural
occurrence of low economic status, mostly associated with low
infrastructural development. In the case of Timor Leste, this was in
the main the result of beng controlled by external political and
military force.
NOTES ON IANA DATABASE:
The current Sponsoring Organization (Laleia) and Admin Contact
details are incorrect. The listed Admin (Xanana Gusmao ) are
incorrect.
A Clarification on the Connect Role
The current details giving an address at Minihub were, as far as I
understand, provided by or on behalf of Xanana Gusmao.
This was done without consultation with us.
The only notification that we received on this issue was by email
from IANA.
The original contact details using Xanana were done in conjunction
with the East Timor Solidarity Campaign in Ireland. The difficulty
was to provide detials of an East Timorese citizen, while avoiding
any repercussions from the Indonesian Military Authorities.
Tom Hyland informed us that he had arranged with local contacts to
inform and arrange with Xanana, who was at that time imprisoned in
Jakarta, his agreement wiht our planned activities for .tp
Subsequent to this, there was a request, not originating from us to
have the contact detaisl changed from a connect id to one at minihub.
I am sure that the records of this change have been kept on IANA
records.
We subsequently received a fax purporting to come from Xanana with a
signature that did not appear to us as an original one appended to
this document. My requests for clarification and confirmation of
this document were not received..
I would also note that we sussequently received a visit in Dublin
from Xanana Gusmao, his wife Kirsty and Ramos Horta, who thanked us
for our activities on behalf of the people of East Timor with the set
up of .tp.
The Sponsoring Organization is non-sensical (its a place
name) and the listed admin ( the President of Timor-Leste) has
never had anything to to with the administration of the .TP ccTLD and
has expressed in the past expressed his strong desire to have his
name removed from the IANA database.
See comments above.
The IANA database should be corrected, if delegation to the .TL admin
is not possible, then it should be delegated back to the IANA "in
escrow" while the .TP ccTLD is phased out. Leaving it in it's
current state is false/misleading erroneous , not in the public
interest and against the wishes of the current listed Admin Contact.
I assume that the change would have been made only after supporting
documentation was provided. Can this be clarified? If not then the
process requires to be tightened as it would be an oportunity for
abuse to occur.
MISC...
- The fact that the IANA database is wrong is problematic in that no
entity is able to provide "authoritative " advice to existing
registrants and registrars on phasing out .TP. The .TL NIC / CoCCA
have been providing advice but do not have enforcement powers - do
not control the .TP zone generation ( do not desire too either) or
so set .TP policy. Existing registrants should be provided formal
advice on the phase out by the listed Admin / Sponsor (not possible
in this case at this time). The IANA should consult with Connect
Ireland, correct the IANA database to some sort of escrow state and
then formally notify existing registrants of the plan...
We have informed IANA of this as an ongoing difficulty as this has
caused management and technical difficulties as well as potential
delays. This was last an issue for us when we needed to move our
addressing due to a change of upstream provider(s).
Thanks Garth and Kim for this opportunity to have an input and also
to clarify our role and activities. .TP was initiated as a social
action and served well as a method of highlighting both the needs and
wishes of the East Timorese ( Timor Leste) people.
The site generated some 32 million hits in 3 weeks, placed East Timor
on the front pages of 96 major media outlets and within 6 days of the
issue of our press release, there was an issue of a statement from
the then Indonesian president offering a limted form of independence.
If .tp has contributed with the many other actions and activities of
to others to achieving the opportunity for the generation and uptake
of democratic processes in one of the world's newest nations, then it
has more than served its purpose well. If our management of .tp has
provided a customer base for the development of .tl, then better
still.
Thanks for the opportunity to input to and hopefully ensure and
increase the ability of managing the fabric that holds the internet
together.
Martin Maguire
Connect.ie, 44 Westland Row, Dublin 2
Tel:+353-1-6763456 Fax:+353-1-6763555
Mob.+353-86-UCALLME (+353-86- 822-5563)
URL: http://www.connect.ie
-Internet for Everyone-