New gTLD Process and IANA-related infrastructure names

[Nate Davis <ndavis@xxxxxxxx>]

The American Registry for Internet Numbers (ARIN) strongly objects to the lack 
of support in the new gTLD process for the protection of IANA-related 
infrastructure names. The recently released "How to Apply for a New Generic 
Top-Level Domain Draft Applicant Guidebook" (draft Guidebook) and the proposed 
generic top level domain Agreement (draft gTLD Agreement) eliminate the 
existing level of protection for some reserved names including those of the 
Regional Internet Registries (RIRs), ARIN, AFRINIC, APNIC, LACNIC and RIPE, 
while preserving protection for ccTLD domains.  The Draft Guidebook and draft 
gTLD Agreement also fail to protect other names of significance to the 
Internet's infrastructure.

Since its inception, ICANN has included protection for selected reserved names 
of IANA-related organizations in registry operator agreements. This protection 
is set forth in Appendix K of the Unsponsored TLD Agreement[1] and Attachment 
11 of the TLD Sponsorship Agreement[2].  These documents identify names to be 
reserved as labels "at all levels" within a TLD. As recently as 3 November 
2007, the ICANN agreement with the registry operator of .MUSEUM included a 
schedule of reserved names protecting ARIN and the other RIRs.

In section 2.1.1.2 of the draft Guidebook, Reserved Names now only appear to be 
protected at the top level.  In the glossary, "Reserved Name" is specifically 
defined as being limited to the top level. In the draft gTLD Agreement, the 
Schedule of Reserved Names to which registry operators are to be bound does not 
have protection for Reserved Names at all levels.  Yet, in Specification 5, the 
draft Guidebook does provide protection for all two-character labels at the 
second-level in gTLD registries, thus protecting all country-code 
infrastructure domains. There is no technical justification to protect one 
class of infrastructure domains but not the other.

We also note other areas of the proposal where attention is needed. Other names 
of significance to the Internet's infrastructure are missing from the list of 
Reserved Names. Neither the .ARPA domain, nor labels within the .ARPA domain 
are included, i.e., IN-ADDR, IP6, E164, URI, URN and IRIS, nor is the term 
"RIR". Furthermore, for those organizations that are included in the Reserved 
Names list, there is no process to have domains released to the appropriate 
entity.

Although responding only on its own behalf, ARIN asks that ICANN take the 
following actions with respect to all of the RIRs in order to protect the 
entire RIR community:

1. Reinstate the existing protection for Reserved Names.
2. Add the following names to the Reserved Names list:
        * ARPA
        * IN-ADDR
        * IP6
        * RIR
3. Develop a process for releasing reserved domains to the appropriate entity.
4. Develop a process for adding or removing names from the Reserved Names list.

We believe strongly that eliminating protection for IANA-related names will 
undermine the security of important infrastructure entities. We question why 
affected organizations were not consulted or even notified of the impending 
change. We further request that ICANN notify us of any changes directly 
impacting our organization.

Regards,

Dale Meyerrose
Major General, USAF (Retired)
Interim CEO, ARIN

[1] 
http://www.icann.org/en/tlds/agreements/unsponsored/registry-agmt-appk-26apr01.htm

[2] 
http://www.icann.org/en/tlds/agreements/sponsored/sponsorship-agmt-att11-20aug01.htm