GeoTLDPriorization Comment

[<sabine.moewes@xxxxxxxxxxxxxx>]

This is a comment of the City of Cologne. We are an applicant for the 
"Geographical Name Top-Level Domain" (GeoTLDs) of .cologne and .koeln. We fully 
adhere all comments which argue in favor of prioritization fo the GeoTLD 
applications.
 
GeoTLDs are important to the respective local communities all over the world as 
they serve and promote the public and the governmental interests. On a focussed 
local basis, GeoTLDs, as .cologne or .koeln are in the interest of the relevant 
national and global Internet community. This gains even more importance for 
international cities as are Cologne or Berlin, whose City and geo applications 
are widely distributed, ensuring fairness and global balance in applicant 
processing. 
 
The City of Cologne is concerned about the public interest not being 
represented properly in the current drawing method. Prioritizing "IDN Top Level 
Domains" (IDNs) is indeed aiming in the right direction to promote public 
interest and to underline ICANN´s plan of a better global outreach, 
nevertheless we want to underline that "Geographical Name Top-Level Domains" 
(GeoTLDs) should be processed in a similar way.
ICANN, as the global guardian of the Domain Name System, has the responsibility 
to ensure a fair balance between public and private interests. The City of 
Cologne clearly operates in the public interest and ICANN should acknowledge 
the support they received by the relevant local authority that was elected by 
the public to serve them and act in their interest. Balancing private and 
public interests, protecting the public interest is to be valued more highly 
than private interests.  To our mind, the proposed drawing method could disrupt 
the balance between public and private interests, as there is a great chance 
that Geo applications, clearly acting in the public interest, may be entering 
the root far behind applications that do not represent the public interest. 
Additionally in terms of public interest, there is no sense in launching 
.COLOGNE (English translation of the city gTLD .KOELN) and .KOELN month apart 
from each other depending in the draw ticket number.
We are convinced that the GeoTLD applications fulfil the requirements set by 
ICANN to give a priority to certain categories of TLDs: to promote DNS 
diversity, make the Internet more accessible, increase avenues of participation 
and serve the public interest. The prioritization of the GeoTLDs along with the 
IDN gTLDs is supposed to better serve the global public interest ICANN 
represents. The explicit support these applications have from their respective 
Public Authorities, the entities entitled at the local level to serve and 
promote the public interest, should be taken into consideration by ICANN in 
order to promote an alignment between the local and global public interest 
spheres.


Therefore we ask ICANN to support the global public interest and to add GeoTLDs 
in its prioritization plan. The prioritization of the 56 GeoTLDs (7 of the 63 
GeoTLD applications are IDNs and already prioritized) would defer the 
allocation of other generic TLDs only for a short period of time. We think this 
is reasonable to protect the global public interest.
With kind regards
Sabine Möwes


Stadt Köln
E-Government und Onlinedienste
Gülichplatz 1-3
50667 Köln
Telefon: 0221 / 221-33989
Internet: www.stadt-koeln.de
E-Mail: sabine.moewes@xxxxxxxxxxxxxx <mailto:ulrich.radermacher@xxxxxxxxxxxxxx>