SIERRA CLUB STRONGLY URGES ICANN TO MAKE A CALL FOR EOIs

[Katrina Svoboda <Katrina.Svoboda@xxxxxxxxxxxxxx>]

TO: ICANN Board members
FROM:  Carl Pope, Chairman, Sierra Club

We fully support a call for Expressions of Interest (EOI) from those that 
have been patiently waiting and intend to apply for new Top Level Domains. 
 We believe new gtlds is in the best interest of all users and we request 
that you expedite the application process and publish a date that you will 
hold firm to.   We have followed the application process and with the 
majority of “overarching issues” close to resolution, we urge you to call 
for EOIs and make accepting applications an immediate priority. 

Dot Eco will contribute much needed funds for the environment and delays 
squander this opportunity as well as the many other benefits other new top 
level domains will give the world.  We believe that the time for new TLDs 
is now, and strongly urge ICANN to take action, accept the EOI and move 
the technology that powers the Internet forward.

In response to ICANN’s request for opinions regarding potential issues 
with accepting the Expressions of Interest, we submit the following 
points.

How do we ensure that participation in the EOI accurately represents the 
level of interest? 

The EOI can do more than measure “interest.” We believe the EOI should be 
used to appraise the viability of intended TLD applicants.  Many 
organizations have already expressed their interest in new top-level 
domains; interest is not enough, ICANN must use the EOI to determine which 
candidates will actually have the ability to complete the application 
process.

The best way to precisely measure the potential outcome of the TLD 
evaluation process is to require EOI participants to pay a fee 
proportionate to the cost of the application. A significant deposit of no 
less than $55,000 will ensure that the EOI is not tainted with respondents 
that are unwilling or unable to withstand the scrutiny of the final gTLD 
evaluation. 

Should only those who participate in the EOI be eligible to participate in 
the first round when the program officially launches?

Absolutely. Without an incentive to participate, there is no reason for 
intended applicants to pay the deposit. If ICANN does not limit the first 
round to EOI participants, we believe the many will skip the EOI resulting 
in an inaccurate measure of interest.




Should a deposit be required for participation in the EOI?

ICANN must require a significant deposit. Again, we believe this is the 
only way to ensure an accurate measure from the EOI.


If there is a fee, under what circumstances should there be a refund?

As a deposit, the EOI fee would not be subject to refund unless ICANN 
failed to begin the gTLD evaluations within a reasonable time frame.

What information should be collected from EOI participants?

We believe that the deposit will be enough to guarantee the validity of 
the intended applicants. Therefore, any additional information should be 
kept to a minimum. We propose only requiring applicant name and the 
applied-for string. This information should also be made publicly 
available. If ICANN is to begin with Expressions of Interest, we believe 
the process should be as transparent as possible.

Must the responder commit to go live within a certain time of delegation?

Any organization that expresses interest should have the ability to go 
live within a reasonably short timeframe.   We wish to go live with .eco 
as soon as possible.  Requiring a deposit will help to ensure that 
applicants that are not sufficiently prepared are barred from 
participating.

What are the implications for potential changes to the Applicant Guidebook 
after the EOI participation period closes?

To obtain a precise survey from the EOI, participants must know what to 
expect from the process. It is therefore imperative that the Applicant 
Guidebook be changed as little as possible following the acceptance of the 
EOI.

What are the potential risks associated with the EOI?

The main risks we anticipate is not with the EOI, but with further delays 
due to corporate lobbyists and fear mongers.  There are many non-profit 
organizations, such as us, that will benefit from community-specific TLDs. 
Community gTLDs will be an important part of the Internet as consumers 
look for new ways to connect with organizations and businesses that share 
their philosophical ideals.

The world is becoming more “local” everyday. Individuals are forming new 
tribes online that are not based on location, but on their passionate 
support for causes like the environment. As an international advocacy 
group, the Sierra Club knows how true this is. ICANN must address this 
shift by adopting new Top Level Domains that reflect how people are using 
the Internet every day. 

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Katrina Svoboda
Licensing & Membership Marketing Coordinator
Sierra Club
p: 415.977.5635
f: 415.977.5797