Re: Retiring ccTLD's - observations/notes on .TP

["mmaguire@xxxxxxxxxx" <mmaguire@xxxxxxxxxx>]

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-