Comments Against Approving the .post Application
I want to thank ICANN for giving me the opportunity to express my concerns about the application submitted by the UPU for the proposed sponsored .post domain. With all due respect to the UPU and the postal community, I believe that ICANN should deny this application. Many of the issues presented in the UPU application need to be addressed and resolved. The need for a united postal community is extremely important. However, having a sponsored .post domain as presented by the UPU is not the vehicle for resolving these issues. I have four concerns which I will address and I hope that ICANN will seriously consider them before making a final decision with regards to the UPU application.
I am most concerned that the UPU application for the .post domain is a direct challenge to ICANN's authority. The application states that "The POC will be responsible for formulating and overseeing the policy of the .post sTLD". The UPU is the POC which is fine, but there is no place in the application where the UPU recognizes ICANN as having any jurisdiction over the UPU with regards to it being a registry or that it will accept ICANN's policies and procedures. In the application, the UPU has approved SWITCH to be the .post registry. By fiat, SWITCH is the registry. There is no place in the application that states that SWITCH will adhere to ICANN policies and procedures. Nor is there any statement directly from SWITCH stating that they will adhere to ICANN policies and procedures. In fact the application states that the UPU will set its own policies and procedures, including its own Uniform Domain Name Dispute Resolution Policy that will be based on ICANN's dispute policy, and its own whois. This application is a self-serving attempt on the part of the UPU to legitimize establishing its own little Internet structure under its own rule which in essence will act independently from the Internet which is being overseen by ICANN. The UPU is trying to set up an all roads lead to the UPU type of a scenario. If this application is approved, it will establish yet another huddle that ICANN will have to overcome in its attempt to bring standardization and harmony to the Internet. Overseeing the Internet is the responsibility of ICANN and it should be kept that way. Also, it will "box in" the postal community and leave the community at best with limited options in which to operate on the Internet.
My second concern is that the UPU is proposing under the 3-letter country code designation instead to the traditional 2-letter country code. Using the 2-letter country code designation has been a long established Internet policy. UPU states that for the .post domain it will use the 3-letter country code designation which is in direct contradiction to ICANN policy and how the Internet operates. There is no reason why the UPU can not use a 2-letter country code designation and conform to the rest of the Internet Community. One has to ask why they are trying to introduce something that is contrary to current standards that everyone has accepted? This simply makes it harder for everyone.
My third concern is the accrediting of registrars. The application states "Accreditation will follow a regorous selection process to be established by the POC and operated by the IB." In addition, it states that "The UPU will approve registrars wanting to offer .post registration services." Finally, it states that "Initially, the UPU will grant registration for .post domain names to all the world's DPOs and Regional Unions without exception. Subsequently, the postal community at large will be able to register domains." Based on the application, as far as accreditation is concerned the UPU would have final say, not ICANN. Just because you are an ICANN accredited registrar does not mean that you will be approved by the UPU. By establishing themselves as the accrediting authority, again they are directly challenging ICANN's authority to oversee the Internet. I find this most disturbing. ICANN should be accrediting registrars, not the UPU, regardless of the domain. Further, ICANN should be the only accrediting authority.
My final concern is that the application states that "The UPU has examined the opportunity to work with the present TLD environment to determine if global universal postal services could be implemented within these structures. Our conclusion is that the only secure and stable way to create a universal electronic postal service, that would fulfill the expectations of the world's citizens and governments, could only be achieved under a sponsored TLD." I disagree. The application while vague does provide a glimpse of a very complex registration process. None of this is necessary. It is only required if you plan on operating outside and in parallel with the existing Internet. The application defines who and what is eligible to have a .post domain name. While they stop at 11 definitions, many of which are vague. The definitions cover just about everything except the individual person, the very reason for having a postal system. If you look at the examples of the domain structure for these definitions, all of these definitions can easily be covered buy existing domains many of which are already under ICANN control.. All the definitions and their purpose can be handled by adding the .post sublevel or secondary level domains to the existing TLDs. The .post sublevel or secondary domain would be restricted to postal use. For example, each country could use its own country code domain, the ccTLDs, for example, <.post.us> Whether is would be a sublevel or secondary level would depend on the current structure to the ccTLD. By taking this approach it recognizes the sovereignty of the each country and its postal services. While this approach does not solve all of the issues that are brought out in the application, it does provide a means for uniting the postal community and allow each country to have a say in its postal operations on the Internet. It would allow each country the freedom to have its own say on how the postal community will unite and the standards that they will employ, rather than having standards, policies and procedures forced on to them through a .post domain under the control of the UPU.
Using country code TLDs does not address all of the UPU definitions or issues, for example the International definitions. These could be handled by adding the .post to the .int domain. Also, the application addresses "postal partners". From the examples, it is suggested that this are companies which provide postal services. These companies already have a presence on the Internet using an existing domain. It would be much simpler to add <post.> in front on there current domain name and reserve the post. for postal purposes. Bottom line there is no real need for a .post domain. The structure for a united postal community is already in place. All the postal community has to do is use it. The challenge will be on how to use it, but this should be determined by the postal community as a whole, not just the UPU.
In conclusion, I strongly feel that the application should be denied. It challenges ICANN's authority and attempts to undermine and imped ICANN in achieving its objectives. The issues facing the postal community can be resolved by using the existing infrastructure of the Internet and the currently established TLDs. Where as, the application enables the UPU to govern the postal community, rather than allowing the postal community to govern itself. It is one thing to be a vehicle to support and help the postal community. It is quite another to force and dictate how it will operate. There is simply no need for a specially sponsored .post domain as presented by the UPU. It is my opinion that what is being proposed will in the long run hurt the postal community more than it will help the community.
Steven R. Coates