Comments on the new gTLD process

["Asociación PuntoGal" <prensa@xxxxxxxxxxxx>]

Comments on the new gTLD process



PuntoGal is an initiative in favour of an Internet domain (.gal) for the
Galician language and culture, a community with approximately 4 million
speakers spread around the world.



While we would like to thank ICANN for the hard work and all the efforts
they've put into developing the draft RFP, there are some aspects, which we
find disquieting.



**

*-Timeline*

Our first concern regarding the draft RFP is that there are absolutely no
timelines at all. (See page 1-1 Draft RFP:  "The application submission
period opens at [time] UTC [date].") As we can see, the time and date boxes
are empty.

All we have to go on are the anticipated timelines announced by ICANN at the
most recent international public meetings.

PuntoGal has attended the last six ICANN international public meetings, from
Lisbon in March 2007 to the latest one in Cairo. Let's have a look at the
following data to refresh our memories:

ICANN's 30th International Public Meeting, LA, October 2007: ICANN points
out that the application period could open around summer 2008



ICANN's 32nd International Public Meeting, Paris, June 2008: ICANN delays
the process and announces the application period is likely to open around
Spring 2009



ICANN's 33rd International Public Meeting, Cairo, November 2008:  the
anticipated timeline shows now that bidders could submit their applications
sometime during CQ3 2009.



So, it seems we will finally be able to present our applications sometime in
Fall 2009, But can we trust this timeline? If the previous timelines
announced by ICANN are anything to go by, NO, we certainly can't.



PuntoGal will apply for a community-based domain and there is a whole
community eagerly awaiting the launch of the .gal, asking when will this
initiative become real, when will this dream become true.

Hand in hand with the expectant community, PuntoGal Association has been
working for nearly 3 years now in preparing a draft application, promoting
the initiative within the community, carrying out fund-raising activities to
cover the application costs, etc. This means a lot of costly effort and hard
work indeed. That's why we ask ICANN to open the process ASAP, by CQ3 2009
the latest. Anything longer than that will be harmful for ICANN, the whole
Internet community and us.





*-Fees and payments*

Our second comment refers to the application fee, estimated 185,000 USD (see
page 1-19 Draft RFP).

We are looking into the possibilities of raising the money to cover the
cost. After the work we've been carrying on, we hope and we believe we will
be able to pay this fee, although we still think it is quite a lot of money,
specially for bidders and initiatives representing linguistic and cultural
communities which won't follow the .com model.

 What about applications from developing countries or regions? Isn't this
amount of money far too high? As ICANN says (see "Cost Considerations of the
New gTLD Program" page 4): "(..) financial requirements and fees might
discourage applications from developing nations, or indigenous and minority
peoples, who may have different sets of financial opportunities or
capabilities relative to more highly developed regions of the world". Here,
ICANN has hit the nail on the head and, although it "takes these concerns
seriously" and will "explore possibilities for future means of financial
assistance for a fee reductions to qualified applicants for new gTLDs" in
the future, they should consider reducing it now, in order to allow not only
more innovation, choice and change to the Internet's addressing system, but
also to promote a more democratic, global, multicultural and multilingual
Internet.



Another remark regarding the economic aspects: the 75,000 USD annual
registry fee to be paid to ICANN (see "Cost Considerations of the New gTLD
Program", page 10).

This is a really large fee for small or medium size registries, especially
those representing non-profit making linguistic and cultural communities,
whose goal is simply to serve their community.   ICANN might like to
reconsider this point, and perhaps establish a variable registry operator's
fee.









-*Community-based gTLDs*



As stated in the draft RFP, community-based gTLD applications are those
applications for a gTLD "operated for the benefit of a defined community
consisting of a restricted population". This type of applicant "will be
asked to substantiate its status as a representative of the community it
names in the application, and additional information may be requested in the
event of a comparative evaluation". According to this definition,
community-based gTLDs have very well defined characteristics. They are
intended to serve a concrete, specific community, and their aim is to
represent this community on the Internet, and be assigned a specific place
on the Internet for this community.



For example, with .gal, the Galician cultural and linguistic community would
have a home of their own on the Internet, attaching importance to its
language and culture in the global world.

The draft RFP indicates that community-based applicants are expected to
demonstrate certain requirements or conditions (see Module 1, article
1.2.2.1 "Definitions", page 1-12), such as prove an ongoing relationship
with a defined community that consist of a restricted population.



It seems that the requirements for the community-based gTLDs are clear and,
as we mentioned before, this type of applications have very well defined
characteristics, objectives, etc. Therefore, as we think the evaluation
process will be easier to carry out with applications for community-based
gTLDs than for open gTLDs, we suggest ICANN open the round for
community-based gTLDs first, before the proposed estimated time, in order to
speed up and facilitate the process, as petitioners are already prepared to
submit their applications.



If this is not the case and open gTLDs and community-based gTLDs submit
their applications at the same time, when there's a conflict or dispute
between two applicants (one open and the other one community-based), we
suggest that priority be given to the community-based gTLDs, as they have to
respond to special requirements.











Finally, we thank you for the opportunity to have our say on the draft RFP,
and hope our comments will be taken into account.