CNNIC's Comments on V3

["Tan Yaling" <tanyaling@xxxxxxxx>]

As one of the pioneers on IDN, CNNIC has been very active in the IDN test
and Policy Development Process of ICANN. CNNIC is inspired that the
long-awaited fast-track IDN ccTLDs will finally be implemented within this
year. With respect to the newly released Implementation Plan Version 3, we
have the following comments:

1. on variants treatment
In the "Proposed Implementation Details Regarding: Development and use of
IDN Tables and Character Variants for 2nd and Top Level Strings?, it
mentioned to use aliasing to resolve variant issues. However, it is proven
by the technical community that aliasing is not the workable solution. 
The current best practice developed by technical community is using the
ns-record technique and combine with related registration policy. Please
refer to IETF standard RFC3743, and more specifically to Chinese, the
RFC4713. CNNIC has been practicing IDN registration since year 2000. For
close to a decade, we?ve been dealing with variants registrations both at
the second level and top level. It?s proven that proper registration policy
can handle the variant issues very well.
We strongly recommended that variant strings should be delegated to the same
IDN ccTLD Manager through one application. And for practical reasons, IDN
ccTLD managers should have the prerogative to choose which variant strings
it wants to be active and which it wants to be blocked. The IDN Registry
would then be able to offer the active strings to end-users when they apply
for an IDN domain. Any possible issues at the second and third levels caused
by use of variant strings at the top level should be left to the registries
to resolve either technically or by adopting certain policies.

2. on financial contributions
CNNIC, in collaboration with CDNC has been developing the technology and
standards for CDNs for quite some time.  The developed technical standards
are shared with IDN stakeholders without any charge.  We regard it as a
social responsibility to boost the adoption of IDNs in the community and
hence lift the barrier for local users. When ICANN does its cost recovery
calculation, we thought it?d be fairer to take the contribution the
community has made into its consideration. 

There is a huge diversity of ccTLDs in the AP region.  Most of them are very
small and operate in a non-profit mode. And some are planning to operate
several IDN ccTLDs. Current cost recovery and application processing fee
will pose a multiple burden on the operators, which will be caught in bad
financial situation and will eventually do harm to the Internet users.

In this context, we urge ICANN adopt voluntary contribution model rather
than compulsory for IDN ccTLDs.

3. on DOR
We welcome the flexibility of ICANN on the format of DOR. We want to
reiterate and echo GAC Sydney communiqué that DOR ?should not be limited
only to the 2 mentioned forms but may also extend to include other options
that may exist and may be more suitable to some ccTLD managers.? In the
meanwhile DOR ?should not delay the whole process of the Fast Track?.

4. on timing
Fast track is meant to meet near term need and is open for the registry who
is ready. We don?t think a prolonged process hoping to solve all problems at
this stage is a desirable solution for Fast track. Given the fact of
readiness of certain registry and the long-waiting of the Internet users, we
sincerely urge ICANN launch ccTLD fast-track no later than Q4 2009 so that
eligible IDN ccTLDs will be able to proceed as a real fast track.

5. on revision of IDNA Protocols
We understand that the IDNA protocols are currently under revision, but The
IDN ccTLD fast-track process should not be held back by this revision.
Fast-track is a case by case delegation, and application will be reviewed
under all current criteria to ensure the safety and stability of the
Internet.  We know IDNA protocols are revised from time to time. We just
can?t wait for the endless revision without doing anything.
And if there?s any change on IDN, we?re sure it will be reflected and
respected by IDN ccTLDs soon enough because it is the Internet, the stable
and safe Internet that we all share and cherish.

Thank you!


Tan Yaling
China Internet Network Information Center
www.cnnic.cn