Re: [soac-newgtldapsup-wg] Draft summary of public comment (second milestone report) ready for JAS WG review

[Elaine Pruis <elaine@xxxxxxxxxxxxxxxxxxxx>]

Packet Clearing House is a non-profit research institute that supports  
operations and analysis in the areas of Internet traffic exchange,  
routing economics, and global network development.
      Originally formed in 1994 to provide efficient regional and  
local network interconnection alternatives for the west coast of the  
United States, PCH has since grown to become the leading proponent of  
neutral independent network interconnection and provider of route- 
servers at major exchange points worldwide.
      Today, PCH provides equipment, training, data, and operational  
support to organizations and individual researchers seeking to improve  
the quality, robustness, and accessibility of the Internet.	       
Current and ongoing PCH projects include the construction of  Internet  
Exchanges Points (IXPs) throughout the developing world; operation of  
the INOC-DBA global Internet infrastructure protection hotline;  
support for globally distributed domain name system (DNS) resources;  
implementation of network research data collection initiatives in more  
than three dozen countries; and the development and presentation of  
educational materials to foster a better understanding of Internet  
architectural principles and their policy implications among policy  
makers, technologists, and the general public.
Packet Clearing House is a non-profit research institute, with ongoing  
projects to help construct IXPs throughout the developing world. They  
have provided free DNS services to many under-resourced ccTLDs.  Bill  
Woodcock is the authority and driving force on making sure developing  
nations have stable access to the internet.   It would be a grave  
error to dismiss his recommendations and insight as not having "any  
obvious rational basis for being posted."
Elaine

On Aug 3, 2011, at 7:53 AM, ebw@xxxxxxxxxxxxxxxxxxxx wrote:

> Karla,
>
> I'm going to address one single comment in an attempt to point out a  
> larger
> issue.
>
> Writing for Packet Clearing House, a corporate entity providing fee- 
> based
> network services, Woody opposes an exception to a condition we have  
> some
> basis for belief is significantly more difficult to satisfy in  
> developing
> economies than in developed economies -- the v6 requirement for  
> transition
> to delegation.
>
> Woody claims it is harmful to applicants to associate a feasibility
> condition to the v6 requirement.
>
> Fine.
>
> You've caught that in the recital, the summary, of Woody's comment.  
> What is
> lacking is the analysis, which as you point out in Actions needed,  
> item #2,
> needs to be drafted.
>
> Woody's claim is that the applicant is _more_harmed_ by an exception  
> to the
> v6 requirement than the applicant is harmed by the loss of its  
> investment
> in applying. That is what "harmed by exception" really means as the  
> basis
> for opposition to exception to a condition over which the applicant  
> has no
> feasible means to satisfy.
>
> So assuming the most generous scenario available, the applicant has  
> invested
> $45,000 USD in an application fee payment to ICANN, and at least  
> another $1
> USD in preparation cost, possibly more, but just to use round  
> numbers, a sum
> of $50,000 USD.
>
> Woody's claim is that the cost to the applicant to meet the v6  
> requirement
> at some later date is greater than the $50,000 USD, and all "good  
> will" (the
> usual form of expression of identity of a resource to its users) and  
> use of
> revenue, and net profit, from operations, from 1Q2013 to the date  
> the v6
> requirment can be met, some number of fiscal quarters.
>
> This is a testable claim. What is the industry average cost for a  
> small to
> medium sized business to add v6 prefix advertizment, and v6  
> endpoints, for
> its principal computer centered operational activities? If adding v6  
> costs
> more than $50,000 for the average small to medium sized business,  
> then Woody
> has valid point.
>
> If it costs less than that, then whatever "harm" Woody is arguing,  
> is harm
> to some other party, assuming there is a demonstrable harm  
> eventually, and
> not relevant to MR2.
>
> Our analysis has to test the comments for their possible rational  
> meaning,
> and we may find that some resist finding any obvious rational basis  
> for
> being posed.
>
> Eric
Elaine Pruis
VP Client Services
elaine@xxxxxxxxxxxxxxxxxxxx
+1 509 899 3161