APTLD's Comments to the 3rd Revision of the IDN ccTLD Fast Track Implementation Plan

[Ramesh Kumar Nadarajah <ramesh@xxxxxxxxx>]

To ICANN:



APTLD is pleased to submit comments to you on the *3rd Revision of the IDN
ccTLD Fast Track Implementation Plan*.



We support the IDN ccTLD Fast Track initiative and are eager to see it being
implemented as soon as possible, not least within the timeline already
published. Our specific comments regarding the 3rd Revision of the
Implementation Plan are as follows:





*(1) Documentation of Responsibility (“DoR”)*



In the "Proposed Implementation Details Regarding: Arrangement between ICANN
and prospective IDN ccTLD  managers (29 May 2009)”, a mechanism of "*express
acceptance of specific terms and conditions describing the TLD obligations
when signing the TLD request*" was proposed.



We note that many of the existing ASCII ccTLD registries have been
administering their domains successfully for a long time without a formal
agreement with ICANN or IANA. Similarly, registries of IDN ccTLDs should not
be required to sign a formal agreement (DoR) before they can operate their
IDN ccTLDs.



In our view, the approach of ICANN encouraging the ccTLD manager to enter
into a DoR or other form of agreement on a voluntary basis should be more
palatable for ccTLDs. We would support such an approach.





*(2) Variant Strings*



In the "Proposed Implementation Details Regarding: Development and use of
IDN Tables and Character Variants for 2nd and Top Level Strings”, our views
on variant strings are that they should be delegated to the same IDN ccTLD
Manager who, for practical reasons, should have the prerogative to choose
which variant strings it wants to be active and which it wants to be
blocked. There are genuine needs for certain countries and territories to
deploy both the normal string and variant strings as their IDN ccTLDs. 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.





*(3) Cost*



In the "Proposed Implementation Details Regarding: Financial contributions
to Support the Development and Deployment of IDN ccTLDs”, ICANN has
identified three cost components:

1. Cost associated with processing requests for new IDN ccTLDs;

2. On-going IDN ccTLDs support costs; and

3. Relevant costs associated with development of the overall IDN programme
and the Fast Track programme.



Component 1. is considered in more detail in (4) below. For component 2,
there needs to be greater clarity and transparency. For component 3,
development costs have already been expended by ICANN. Individual ccTLDs
have also incurred their own development costs. Going forward, it would seem
unfair for ICANN to include its development costs into the proposed cost
contribution model for IDN ccTLDs.



We acknowledge the Security & Stability Advisory Committee's work towards
standardizing the display and usage of "Internationalized Registration
data". Even though no standards or guidelines exist for internationalized
registration data, some ccTLDs in Asia-Pacific have invested in WHOIS for
IDN development & deployment and will continue to invest in the future
upgrades, where necessary. Such significant amount of investment should also
be taken into consideration by ICANN.




*(4) Pre-arranged, Recommended Contributions*



In the "Proposed Implementation Details Regarding: Financial contributions
to Support the Development and Deployment of IDN ccTLDs”, the term
"*pre-arranged
and recommended contributions*" is used. This term is somewhat unclear and
confusing but it seems to suggest that contributions by IDN ccTLD registries
are actually voluntary. Greater clarity is therefore desirable. If the
intention is to have the contributions voluntary, we would support it. Our
rationale is as follows:



Firstly, for consistency, IDN ccTLDs should still be similarly treated as
ASCII ccTLDs and hence contributions should remain voluntary.



Secondly, unlike gTLD registries which are profit-making, many ccTLD
registries are non-profit in nature. In the Asia Pacific region, many ccTLDs
are small and require regular sponsorship to continue to operate.  Also,
some registries do not plan to charge for their IDN ccTLDs, or charge
nominally only. The intention of these ccTLDs is to bridge the digital
divide that exists in many parts of the region. Imposing a compulsory fee is
tantamount to depriving countries or territories of their rights to have
their ccTLDs in their own languages.



Finally, as mentioned above, many ccTLDs (e.g. those involved in the Chinese
Domain Name Consortium) have already expended costs in relation to
developing technical standards and implementations for IDNs for their
respective communities. In a number of instances these solutions are being
shared with others in the Internet community, including gTLD registries,
without charges or cost recovery. It would be unfair  to now impose a
compulsory fee on these registries.




*(5) Revision of IDNA Protocols*



The IDN ccTLD fast-track process should not be held back by the coming
revision of the IDNA protocol.  Protocols are never perfect and revisions
occur every now and then.  The Chinese domain name communities have launched
their Chinese domain names at the second level based on earlier versions of
the protocol with no problems or issues. The need for a stable system is
recognised and the ccTLDs are sufficiently responsible to ensure that the
protocols implemented do not endanger the stability of the Internet.





*About APTLD*



The Asia Pacific Top Level Domain Association is an association of country
code top level domains (“ccTLD”) managers, and other organisations that have
an interest in ccTLDs, in the Asia-Pacific region. Our aim is to assist our
members to operate world class ccTLDs.



Thank you for the opportunity to make this submission.







Ramesh Kumar Nadarajah

General Manager