THE ENVIRONMENT NEEDS .ECO NOW!
Following my disappointment at the delay in the new TLD application process, I am writing to express my full support for the proposed plan to accept Expressions of Interest (EOI). My reasons and suggestions for an EOI model are included below as responses to ICANN's questions regarding possible issues. How do we ensure that participation in the EOI accurately represents the level of interest? In order to ascertain an accurate level of interest the EOI should resemble the actual gTLD process in certain ways. This means, specifically, that intending applicants should be required to pay a sizable, non-refundable fee. Without becoming unduly burdensome, the EOI process must include enough financial risk to weed out unserious applicants -- those that say they want to apply for a new TLD, but are, in truth, incapable of financing or organizing such an endeavor. I believe the best way to accomplish this is for ICANN to require a portion of the application fee upfront. A deposit of ranging from 35% to 50% of the application costs will indicate that the intending applicant has the financial wherewithal to complete the process. Should only those who participate in the EOI be eligible to participate in the first round when the program officially launches? Yes, only EOI participants should be allowed to participate in the first round of TLD applications. This is more than just an incentive. Limiting the first round of applications to the EOI group will streamline the overall process because only the most prepared applicants will participate. By restricting the applicants, ICANN will have the opportunity to determine not just "real interest" but also the actual number of applications it will receive. ICANN will then be able to accurately prepare for the first round of gTLD applications. Should a deposit be required for participation in the EOI?Emphatically yes. As stated above, a deposit ranging from 35% to 50% of the application costs will show that the intending applicant has the financial wherewithal to complete the process. If there is a fee, under what circumstances should there be a refund?The EOI participation cost should be considered a portion of the evaluation fee and subject to the same rules. What information should be collected from EOI participants?5.1 What subset of applicant questions found in the Applicant Guidebook at http://www.icann.org/en/topics/new-gtlds/draft-evaluation-criteria-clean-04oct09-en.pdf should be answered? I propose that the applied for string should be indicated, but beyond that, little else. 5.2 Including applied-for strings? Yes. 5.3 Should information be made public?Yes! Making the information public will (again) weed out applicants that are not adequately prepared for the challenges of administering a top level domain. Overly optimistic applicants will be able to compare their readiness against the competition and decide whether to move forward or withdraw without incurring additional financial risk. Must the responder commit to go live within a certain time of delegation? In my view, by participating in the EOI and pre-paying a portion of the evaluation fee, applicants are not merely expressing interest:, they are announcing their intent. As such they should agree to have their TLD applications ready within a reasonable period of time after being given the green light from ICANN. By announcing a clear, yet brief, timeline, ICANN can preserve the opportunity to determine and evaluate interest, and still move quickly to bring new gTLDs to the public marketplace without costly delays to the communities and governments that have spent valuable time preparing for this process. What are the implications for potential changes to the Applicant Guidebook after the EOI participation period closes? The EOI model should be used to ascertain levels of interest for the gTLD program as it is now. If enough interest is not shown in the current application process, only then should ICANN consider potential changes to the Applicant Guidebook. As I have watched the process move forward, it has become apparent that more communities and geographic areas are awakening to the benefits of identifying their population with its own gTLD. I strongly anticipate that there will be many intended applicants with the current Guidebook in place. What are the potential risks associated with the EOI?The risk I foresee with the EOI is that the delay will cause unexpected hardship on gTLD applicants. While community applicants are often financially prepared to accept delays, geographic designations are more vulnerable. Many cities and regions will benefit greatly, not just from their own Internet identity but also from the much needed revenue that the gTLD will generate. However, I believe ICANN has the power to mitigate the potential risks, by committing to a shortened application timeline following the EOI. Sincerely, Jim Dufour Principle Development Engineer Associate Director Instrument Development Group Scripps Institution of Oceanography UC San Diego |