Please avoid unnecessary regulations

[Stephane Bortzmeyer <bortzmeyer@xxxxxxxx>]

Thanks for the technical analysis in report SSAC 053 on one-label
domains ("dotless domains"). The analysis is mostly correct.  We
nevertheless note that there is an outdated reference to the SMTP RFC
(it is now RFC 5321) and that we cannot find, in this RFC, a
prohibition of dotless domains (a chapter-and-verse reference would
help locate it, if it exists).

The SSAC 053 can be summarized as "Domains of only one label may not
work as you expect in the present world, so, users, beware". We agree
with this observation.

But the conclusion (forbidding A, AAAA and MX records at the apex of
TLDs) does not follow from these premises. A TLD with such records may
experience difficulties but it will only affect the users of this TLD,
not endangering "the security and stability of the DNS". We do not see
it as a threat for this global security and stability. We do not think
it is a good idea to add yet another mandatory rule to the requirments
for the new gTLDs. There are already a lot of regulations.

We observe that five members of CENTR (the association of European
ccTLDs) have a A, AAAA or MX at the apex (ac/sh/io, dk, hr, va and
gg/je) and we note it did not create problems.

Statement of Interest
*********************

AFNIC is a not-for-profit, multistakeholder organization founded in
1997, managing the French country-code top level domains .fr, .re,
.tf, .wf, .pm and .yt. AFNIC is a member of ccNSO and a founding
member of CENTR, the European regional organization of ccTLDs
gathering 57 ccTLD managers.  AFNIC is involved in the new gTLD
process as a registry backend services provider. Seventeen (17) new
gTLD applicants have selected AFNIC's registry solutions to run their
TLD.

AFNIC comments on the new gTLD process are made on its own behalf and
should not be considered as the expression of its clients' views.