Comments on Delegation Rate Scenarios
- To: delegation-rate-scenarios@xxxxxxxxx
- Subject: Comments on Delegation Rate Scenarios
- From: Jon Nevett <jon@xxxxxxxxxx>
- Date: Fri, 5 Nov 2010 10:26:56 -0400
I would like to commend the ICANN staff on the Delegation Rate Scenarios for
New gTLDs report issued last month. It is a well-conceived technical plan to
deal with the introduction of New TLDs.
The interaction between the timeline work plan that the ICANN Board approved on
certain time periods referenced in the report, however, does require some
First, there is a reference to a 90-day application window in the report. In
prior presentations and discussions with ICANN staff, a 30-day application
window had been discussed. I'm not sure how the 30 days turned into a 90-day
window in this report. Tacking a 90-day window on after a four-month
communications period does not make sense and is extremely unfair to
applicants. There is no need for such a long window in that the vast majority
of applicants would wait for the end of the window to apply anyway. According
the the DAGv4, there is no benefit to applying early so why would an applicant
pay $185,000 to ICANN early and risk the potential disclosure of its string?
If most would apply at the end of the period anyway, then we might as well keep
the window open for a short period of time.
Also, ICANN first announced the introduction of New TLDs in June of 2008.
Based on that announcement, many folks started planning for New TLDs at
incredible expense. They have been waiting -- some more patiently than others
-- to apply. It would be quite punitive to these applicants to have a full
seven month period between the final approval date and when they likely will
apply. The GNSO guideline suggested that "[t]he application submission date
will be at least four months after the issue of the Request for Proposal" -- it
says nothing about the window being as long as 30 or even 90 days. Thus, it
makes the most sense to have the window open for only a 30-day period starting
at the end of the communications period.
If ICANN is convinced that an application window longer than 30 days is
necessary for some unexplained reason, then there is no reason why ICANN can't
start accepting applications during the communications period as long as the
deadline is after the close of the period. For example, the first 60 days of
the application window could coincide with the last 60 days of the
communications period, still giving applicants a full 30 days after the close
of the communications period to apply.
The only argument I have heard for a three-month period after a full four-month
communications period is that someone might hear about New TLDs for the first
time during the communications period and need the full 90 days to apply.
Therefore, the seven-month period is necessary in order not to exclude them.
The fallacy in that argument is that it is a slippery slope -- if you hold the
window open for a year maybe somewhere somebody will hear about the opportunity
and be able to apply then -- where do you draw the line? The GNSO drew it at
four months -- we shouldn't almost double the GNSO recommendation. ICANN has
been announcing the introduction of New TLDs since 2008. The four-month
communications period recommendation was added in 2007 when we thought that the
process would be over in 2009. The costs to folks who have been planning for
the application round and those waiting to decide what to do would far exceed
the cost of someone not applying because they had a four-month period vs. a
seven-month period to apply. Finally, ICANN is planning on having multiple
rounds of New TLDs. Thus, if a person misses this round, they always could
apply in the next round.
The second timeline of concern mentioned in the report is the five-month period
for initial evaluations and the suggested eight-month period between
application and delegation for even the most simplest application -- the ones
that have no objections and have the same technical back-end information as
likely dozens previously reviewed. ICANN needs to strive to do better on these
time periods. My hope is that ICANN is being incredibly conservative in these
estimates and plans to be more efficient. Considering the 10% unemployment
rate in the United States, ICANN should be able to hire sufficient qualified
staff to get this done on timely basis. ICANN refers to a 250 day work year in
the report. There is no doubt that many qualified folks would be happy to work
on weekends during this economic climate. Let's let them.
Let's stop punishing applicants by sucking them dry of all of their working
capital by creating a seven-month communications/application period followed by
a minimum eight-month review period piled on the years that they already have
been waiting. We could do better.
Thanks for your consideration.
President, Domain Dimensions, LLC