Comments on Supporting the Domain Name Industry in Underserved Regions

[Michele Neylon - Blacknight <michele@xxxxxxxxxxxxxx>]

I am submitting these comments in my capacity as founder and CEO of Blacknight, 
an ICANN accredited registrar and hosting provider based in Ireland.

The topic of "underserved" regions has been a subject of discussion for some 
time, however It is not terribly clear what exactly constitutes an "underserved 
region".
What are the metrics?
Number of domains?
Number of registrars?
Some correlation between the number of domains and the population density?
CENTR and other domain name industry organisations have produced a number of 
reports over the last few years to attempt to quantify "domain density". See 
for example:
http://technology.ie/number-of-domains-per-1000-population/

But whether that is a useful metric or not is not clear.
Has anyone looked at linking the cost of domain names and access to internet 
services with the cost of living and average salaries?

Ireland is considered to be a "developed" country, but the average price of a 
domain registration 10 years ago was a limiting factor. At the time the average 
retail price for a one year registration of the local ccTLD was in the region 
of EUR75, while the price of a .com was around EUR15.
At the time there were no Irish ICANN accredited registrars.
However the Irish market wasn't "underserved", as there were (and still are) 
plenty of Irish companies providing hosting, email and other internet services 
either in conjunction with domain registrations in the local ccTLD or in .com 
as resellers of non-Irish registrars.

Specifically in the context of this report ICANN wants to examine the 
accreditation process and criteria that currently exist.

Personally I think that reviewing processes from time to time is a good thing. 
What may have been suitable and appropriate 10 years ago might not be now.
In relation to the current accreditation process I would urge ICANN to examine 
the existing criteria and see if they are suitable in today's climate.
For example, the insurance requirements. Where do they come from? Why are they 
set at that limit? What purpose does it serve?

At a very practical level, why isn't there an actual application form to become 
a registrar? At the moment there are pages of information written in quite 
obscure and technical English, but there isn't an actual form for anyone to 
fill out.
See: https://www.icann.org/resources/pages/application-2012-02-25-en

There are a lot of references to various clauses in the RAA but no real 
explanation in plain English (or any other language) of what is actually being 
asked or what is required. 

Another matter of concern is with respect to "standards". All ICANN accredited 
registrars need to be treated equally and should all be held to the same 
standard. ICANN cannot allow for different treatment of registrars based on 
geographic location or other criteria. 
This does not mean that ICANN should not clarify, educate and conduct outreach 
activities etc., however it would be unreasonable for ICANN to impose stricter 
criteria on most registrars (and their clients) via the 2013 RAA on one hand, 
while simultaneously lowering a barrier on the other.

The ICANN report contains an interesting table summarizing some of the reported 
issues.
Reacting to some of them:
- Onboarding with registries. Prior to the launch of new TLDs onboarding was 
messy and time-consuming. Now with the launch of literally hundreds of new 
registries and domain extensions it has become much worse. ICANN had been 
working on AROS, but it has not been launched nor has it been adopted by any of 
the registries.
- Registry - Registrar Agreements - Having to review complex legal agreements 
is time consuming and costly. While it could be argued that this is a "cost of 
business" it would be helpful if more of the agreements followed some kind of 
standardized approach. While some new TLDs have adopted variants of existing 
RRAs this is not the "norm". However there is a line between what ICANN can 
facilitate and registry operators ability and right to conduct business on 
their own terms.
- Insurance - ICANN might be able to assist registrars to find suitable 
insurance providers where this has proven difficult, but ICANN itself should 
not be getting into the insurance business.
- Funding - ICANN should lead by example. ICANN operates in multiple countries, 
has staff spread across the globe and receives income from many countries. 
However at present all funds must be paid to ICANN in California. If ICANN were 
to accept payment in other currencies and via other banks this might make 
things easier for many registrars and possibly registries.
- Funding - ICANN should not act as a clearinghouse for payments to registries. 
- Costs of accreditation - this might be worthy of review, however I would be 
opposed to ICANN using its funds to finance registrars in "underserved 
regions". Any changes in costs of accreditation need to be applied globally. 
The internet is global. 
- Expertise - outreach and education should be encouraged. 
- Participation - At present most of the materials and communication to 
registrars is in English only and the English itself is generally very legal in 
nature. Providing better materials that are more accessible could go a long way 
to helping reduce issues that result from misunderstandings of registrar 
obligations

During ICANN 50 hopefully there will be further opportunities to discuss this 
topic with ICANN staff and others.

Regards

Michele



--
Mr Michele Neylon
Blacknight Solutions
Hosting & Colocation, Domains
http://www.blacknight.co/
http://blog.blacknight.com/
http://www.technology.ie
Intl. +353 (0) 59  9183072
Twitter: http://twitter.com/mneylon
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Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
Road,Graiguecullen,Carlow,Ireland  Company No.: 370845