Registrar Constituency Position on Proposed IDN ccTLD Fast Track Implementation Plan
Registrar Constituency Position on Proposed IDN ccTLD Fast Track Implementation
Plan
January 7, 2008
BACKGROUND
In November 2008, the members of the Registrar Constituency ("RC") were asked
to provide feedback regarding ICANN's Proposed IDN ccTLD Fast Track
Implementation Plan ("IDN ccTLD Plan"). This Position Paper captures the
overall sentiment expressed by the RC members who provided feedback about this
matter and seems to reflect the general sense of the RC.[1] However, due to
time constraints, no formal vote regarding this Position Paper was taken.
RC POSITION
The RC supports the introduction of IDN ccTLDs. The RC believes that the
introduction of new IDN ccTLDs will have a positive effect on the global ICANN
community. Accordingly, after reviewing the IDN ccTLD Plan, RC members have
raised a variety of concerns.
1. IDN ccTLD Applicants Should Be Responsible For Costs.
The RC recognizes that ICANN is committing significant resources to the IDN
ccTLD initiative, and the RC shares ICANN's commitment to seeing the IDN ccTLD
process succeed. The RC notes, however, that the IDN ccTLD Plan does not yet
specify appropriate financial contributions from IDN ccTLD applicants or
operators. Accordingly, the RC is concerned about other ICANN community
members being unfairly burdened with paying for implementation costs associated
with IDN ccTLDs.
For example, reviewing and processing IDN ccTLD applications will consume ICANN
resources. In the RC's view, IDN ccTLD applicants should be responsible for
paying ICANN's costs associated with evaluating IDN ccTLD applications, not
unlike new gTLD applicants who are responsible for paying fees to cover ICANN's
costs for processing new gTLD applications. Similarly, IDN ccTLD operators
should be responsible for paying a minimum annual fee that is equal to ICANN's
costs associated with maintaining the IDN ccTLD.
The RC recognizes that not all countries possess equivalent financial
resources. In light of this fact, the RC suggests that the ccNSO consider a
funding model that recognizes differences in the ability to pay between
developing versus developed countries, so that the adopted funding model covers
the total costs to ICANN for introducing new IDN ccTLDs.
1. IDN ccTLD Operators Should Have A Nexus With Registrants.
Registrants for a new IDN ccTLD must have a nexus with the country associated
with that IDN ccTLD. In the alternative, a new IDN ccTLD that is intended for
registration at the second level by registrants unconnected with a specific
country should be applied for under the new gTLD process.
1. IDN ccTLDs Should Not Enter Root Before IDN gTLDs.
The RC is concerned about the possibility for unfair advantages being created
based on the timing of IDN ccTLDs and IDN gTLDs entering root. In the RC's
view, there should be no first to market advantage for either IDN. To
eliminate the likelihood of first to market advantages, IDN ccTLDs should not
enter root, whether through the Fast Track process or otherwise, before IDN
gTLDs.
1. IDN ccTLD Operators Must Commit to IDNA Standards.
The RC notes that IDN ccTLD operators must adhere to the Internationalizing
Domain Names in Applications ("IDNA") protocol to ensure the security,
stability and resilience of the Domain Name System. Accordingly, IDN ccTLD
operators should be required to commit to adhering to the current IDNA protocol
as it exists today, along with adherence to updated versions of the IDNA
protocol that may arise in the future.
ICANN should have a re-delegation process established for situations where an
IDN ccTLD operator fails to comply with the protocol. Such a process could
permit ICANN, under its terms and conditions for supporting the TLD in the
root, to initiate a re-delegation process if the IDN ccTLD operator does not
adhere to IDNA standards. The RC suggests that the ccNSO be responsible for
developing an appropriate process to manage re-delegation in the event that an
IDN ccTLD operator fails to comply with Internet standards in this area.
1. IDN ccTLD Operator Selection Criteria Should Be Consistent With New gTLDs.
In order to promote competition and fairness, the technical, operational and
financial criteria set for the selection of an IDN ccTLD operator should be
consistent with the criteria established for new gTLD operators. Eligibility to
apply to become an operator should have criteria similar to the new gTLD
process. Additionally, approved IDN ccTLD operators should be from the
relevant territory or be supported by the local sovereign government, local
Internet business, or local user community.
1. The Term "Operator" Should Be Clarified Where Necessary.
The IDN ccTLD Plan uses the term "Operator" to refer to multiple entities. For
example, the term is used to refer to a "ccTLD Manager," which is the entity
that has a relationship with ICANN (i.e. the entity listed in the IANA
database). Additionally, the term is used to refer to a "Registry Operator,"
which is the entity that is performing the technical functions.
Because the "Registry Operator" is not always the same entity as the "ccTLD
Manager" the RC suggests that ICANN carefully draft the final version of the
IDN ccTLD Plan to avoid language that may confusingly conflate these entities.
CONCLUSION
The opinions expressed by the RC in this Position Paper should not be
interpreted to reflect the individual opinion of any particular RC member.
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[1] Although this Position Paper seems to reflect the general sense of the RC,
during discussions one RC member objected to it.
Attachment:
RC Position - ccTLD Fast Track Implementation FINAL.pdf |