Disapproval of this .tel proposal
I am writing this note in a personal capacity and this reflects my personal opinions. It does not reflect the views of a number of ENUM-related fora and organisations that I am actively involved in though I suspect they may share my opinion. However I do not speak for them. The mapping function proposed for this .tel TLD is essentially identical to that in RFC2916 and already exists under e164.arpa. From that perspective this proposal offers nothing new or innovative. For that reason alone, this proposal should be rejected outright. The proposal ignores a number of very important political and legal considerations that apply to E.164 telephone numbers. These include issues of national sovereignty, data protection, privacy, consumer confidence, competition policy, international and national telephony regulations and so on. This is partially why ITU is involved in ENUM: it makes sure delegations only get made under e164.arpa when the appropriate government approves and allows that government's national resources (E.164 numbers) to be entered into the DNS. No such safeguards exist in this .tel proposal. This would mean that if this TLD was created, a nation's sovereignty will be ignored. Numbers for one country could be entered under .tel without the approval or consent of that nation. This proposal must therefore be rejected. The proposed TLD also violates a fundamental principle of international law: a country's national resources -- in this case its E.164 telephone numbers -- cannot be under the control of another nation. It is highly unlikely any country other than the USA would tolerate the DNS registration of its E.164 numbers to be controlled by a .tel registry that would presumably be owned and operated by Netnumber and Pulver, US companies under the jurisdiction of the USA. Therefore the proposal must be rejected. Further problems exist when national interests are concerned. Many governments, telephone companies and telco regulators are understandably concerned at the integrity of the E.164 numbering plan. This is at the very heart of the world's telephone system. The proposal seems to be offering a free-for-all where anybody can register any string of digits without knowing if (a) it's a valid E.164 number; (b) if the registrant has the right to use that E.164 number; (c) whether any telephone service is provided for that number; (d) the registration would be cancelled if the corresponding telephone number had telephone service withdrawn or transferred to another customer. Unless these concerns are fully addressed, this proposal should be rejected. Other areas of national concern surround issues like consumer protection. The proposal does not seem to offer any redress if someone's E.164 numbers are registered by an impostor and their telephone service is hijacked or redirected to a $100/minute provider operating in say a banana republic. The proposal makes no mention about data protection or privacy. There appears to be no provision for a competitive market for provision of registration services, authentication, applications or DNS service. And no attempt has been made to accommodate the likely differences to markets and monopolies in various jurisdictions. In essense this also means national sovereignty is being ignored. Therefore this proposal should be rejected. The proposal talks of "IP Communications Service Providers" without explaining what these are, the regulatory regime that they operate under, or how some organisation can become an IPCSP. This needs to be clarified. In most countries, telephony services are only provided by licensed operators. It would appear that an IPCSP could well be providing telephone service without complying with a nation's telecommunications licensing policies or following national requirements for universal service provision, emergency service access, lawful intercept and so on. Unless these considerations are fully explained, this proposal should be rejected. The proposal advocates a TLD when no such TLD is needed. A domain name already exists for mapping telephone numbers into the DNS and allowing things like PABX's to do intelligent call routing. That domain is e164.arpa. There is no justification or logical reason for creating another one. In fact, this proposed TLD will only hinder the deployment of ENUM if it was to be approved. The proposal's Conflct Resolution Protocol is inadequate and unsatisfactory. This proposal allows (encourages?) E.164 numbers to be registered without the consent or knowledge of the rightful "owner" of that number. That cannot be right. It is also unacceptable that everyone "owning" an E.164 number would need to repeatedly check its corresponding entry under .tel and then initiate a complaint if they find a bogus registration there. No provision seems to exist for dealing with complaints from people who do not speak English: the majority of the world's telephone users. Finally, if this proposed TLD was created, it would fragment the emerging technology of ENUM and hamper its adoption. Users would be confused as it would not be clear which domain name would be the correct one for any E.164 number: e164.arpa or .tel. Furthermore, if a number was registered in both domains, inconsistencies will arise even if the same entity registered the number in .tel and e164.arpa. This is confusing and will undoubtedly harm consumer confidence. That in turn will discourage ENUM registrations, complicate the development and deployment of software and services around ENUM. Therefore proposed TLD should be rejected even if it had any technical, business, legal or political merit, which it doesn't. It should also be noted that the "Sponsoring Organization Structure" of the proposal lists a large number of companies as attending a trade show organised by one of the companies behind this bid for .tel. This is irrelevant. It appears to be intentionally misleading by implying that these organisations support this .tel proposal. There are few, if any, endorsements from officers of these organisations and companies in support of .tel. |