Fwd: [dns-operations] Re: dotless domains

[Eric Brunner-Williams <ebw@xxxxxxxxxxx>]

Paf, SSAC members, and Staff,

At the suggestion of a ops contributor I'm forwarding my contribution to
the ops list on the substance of the SSAC's recent " Report on Dotless
Domains".

On 2012-09-21 1:11 PM, ebw@xxxxxxxxxxxxxxxxxxxx wrote:
>> Out of 315 TLDs, there are already 17 dotless ones: [list omitted].
> This fails to observe the existence of at least two label allocation regimes,
> one contemporanious with publication of rfc1591 (1994) and one or more that
> were introduced subsequently, by government contractors.  
>
> As Paul observed, and a careful reading of the contractor's performance
> requirement contained in the most recent IANA Function RFI and RFP I and
> RFP II language supports, the policy for the earlier allocation regime is
> independent of a notice and comment period announced by the government
> contractor.
>
> The observation that correct function was not certain was dispositive to
> the decision to bar proposed allocations of labels composed from the range
> 30--39 (ASCII digits).
>
> Independent of whether correct funtion is presently available, allocation
> without sub-allocation vacates policy stated in rfc1591, and restated as
> a government contractor policy document (ICP-1). Neither rfc1591 nor ICP-1
> have been obsoleted by either the IETF or the government contractor.
>
> Independent of the document management policy of the government contractor,
> no notice and comment period is in the record for a policy of allocations
> of labels to private persons for the exclusive use by the private person, of
> which the "dotless" label applications to the government contractor are a
> subset.
>
> I do not share the perspective offered that "there are too many rules",
> nor do I share the perspective that scale is the only relevant engineering
> issue posed by label allocation regimes.
>
> Eric
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Submitted in an individual capacity, with no interest in any of the contracted
parties or applicants to contract materially interested in the 2012 new gTLD
round.

Eric Brunner-Williams
Eugene, Oregon