Personal comments on the Draft Implementation Plan for the IDN ccTLD Fast Track Process

[Eric Brunner-Williams <ebw@xxxxxxxxxxxxxxxxxxxx>]

3.1 Language and Script Criteria

While Northern Syllabics (NS), a script, are used administratively by 
Canada, and Inuktitut in NS has "official language" status in Nunavut, 
Tsalagi is not used administratively by the United States.
It is unclear if representations of "CA" in Cree or Athabascan can be 
accomodated, and it seems unlikely that representations of "US" in 
Cherokee can be accomodated, under the current language of this section.
3.3 Number of Strings per Country or Territory

The UCAS (Unified Canadian Aboriginal Script) project merged the 
syllabic scripts used by Siksika, Cree, Carrier, the Crees, Innu, and 
Inuktitute, comprising several distinct linguistic families. The "one [] 
per official language" is not accomodating, as discussed above. The "or 
one [] script per country or territory" seems unlikely to accomodate the 
majority of Norther Syllabics users (Cree speakers, all dialects, 
discussed more fully on the IETF IDNA WG mailing list in the context of 
identification of punctuation characters and symbolic glyphs in Unicode 5).
While support for North American First Nations / Native American 
non-ASCII requirements may not fall within the goals of ICANN's "Fast 
Track"  Process, these sections are somewhat problematic.
6.1.4 Community/Governmental support

Section 1.7 leaves minority languages which are at best neglected, and 
at worst, the targets of historic and even current efforts at 
eradication, in an unchanged situation.
7.1 Relationship between ICANN and IDN ccTLD operator

As you know, the relationship between ICANN and ccTLD operators has a 
complex, and periodically quite contentious history.
Where a prospective minority language IDN ccTLD operator can not be 
accommodated by the incumbent ASCII ccTLD operator and/or associated 
majority government, an agreement between the prospective minority 
language IDN ccTLD operator and ICANN is an improvement over continued 
denial of service to the minority language community.
7.2 Financial Contributions

The IDN project began with the preemptive deployment of a "Row Encoded 
ASCII" commercial product of Verisign, then the operator of COM, ORG, 
and NET. The non-ASCII language communities have contributed thousands 
of hours of staff time, from the CDNC work during the IDNA2003 period, 
to the present. Staff should not assume that IDN is adding cost, the 
cost was imposed by a commercial party with monopoly powers, and has not 
been funded by the ASCII beneficiaries of the market lockout obtained by 
Verisign and maintained to the present.
ICANN should cost the past value of the CDNC contributions to the 
understanding of the IDN problem, and the current value of the ASIWG 
contributions, and those of others, as well as the value of contributors 
to the IETF IDNA 2003 and 2008 efforts, and to the UTC, to arrive at a 
better understanding of the sunk costs born by non-ASCII applicants.
7.3 Association of IDN ccTLD Operators with the ccNSO

There are no obvious issues of substance here, access to the ccNSO 
technology day at every ICANN is probably the biggest benefit any 
minority language prospective minority language IDN ccTLD operator needs.
7.4 Discussion of Contention Issues with Existing TLDs and new gTLD 
Applications
As you are probably aware, for some minority language communities there 
is the gTLD route to the IANA root, which we used successfully for 
Catalan. My comments on string contention made in the GFA comments apply 
here as well.
There appears to be an error in the text in para 4. The text reads "... 
Fast Track requests are confidential until ..."
The Twomey invite letter allowed responding ASCII ccTLD operators and 
governments to disclose their script and string preferences, and 
alternatively, to keep their preferences confidential. The letter did 
not state that all responses would be held confidential, regardless of 
the desires of the responding ASCII ccTLD operators and governments.
7.5 IDN Table Procdure

Please see the comments of the comments of Erin Chen (TWNIC).

7.6 Proposed Evaluation of Fast Track the Process

We meet three times a year. Having pubic comment once per 12 months in 
lieu of using our face-to-face time is not as flexible as meeting 
continuously, as all other Constituencies, the Board, and the GAC do.
Eric Brunner-Williams
in a personal capacity