ETNO comments on proposed new sponsered Top Level Domains

["Wiedenhaupt, Gerd" <Gerd.Wiedenhaupt@xxxxxxxxxxxxx>]

Dear Colleagues,

on behalf of ETNO, the European Telecommunications Network Operators' 
Association, I submit the ETNO Common Position on both .tel sTLD applications. 
The master document will be available soon on the ETNO website www.etno.be 
under Position Papers.

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 <<...OLE_Obj...>> 
April 2004
ETNO Common Position on the sponsored Top Level Domain applications for .tel 

Introduction
ICANN, the Internet Corporation for Assigned Names and Numbers, invited public 
comments on the new proposed sponsored Top Level Domains (sTLD) in March 2004. 
The two applications that ETNO will make comments on are 

        *       .tel from NetNumber/Pulver
        *       .Tel from Telnic/Telname

It is not intended to make a comparison with ENUM, however the discussions on 
ENUM, as the bridge between traditional PSTN and the Internet, has identified a 
number of issues that, irrespective of the TLD being used, need to be addressed.
Comment on .tel NetNumber/Pulver Application 
The application for TLD states that it is "....to enable IP communication 
Service Providers to register telephone numbers.....". This may be subtly 
different from ENUM, where the responsibility for registering telephone numbers 
is on the individual who has rights of use over the number. 

The NetNumber/Pulver application has no recognition of the personal data that 
can be associated with telephone numbers. In many countries there is data 
Privacy legislation which needs to be taken into account by the applicant, and 
appears to be currently omitted. There are degrees of authorisation which 
reflect the environment in which telephone numbers are assigned and managed. 
Rules, conventions and associated responsibilities exist from the allocation of 
a country code to a national administration, and onwards to telephone companies 
and customers. This is omitted from the NetNumber/Pulver application, and is a 
significant weakness.

The day-to-day control and use of numbers emerges from national structures and 
rules. The assumption of the NetNumber/Pulver application is this situation 
allows for the inclusion of national telephone numbers in any TLD and that such 
inclusion does not contravene national rules and numbering conventions. Whilst 
the inclusion of global numbers e.g. International freephone are not explicitly 
identified in the application, the issues that arise from national numbers 
would also apply to global numbers. This is clearly evidenced by the statement 
in the last paragraph of section D "....As Service providers assign these E.164 
telephone numbers the "day-to-day" control passes from the service provider to 
the individual subscriber or enterprise entity that has requested service. 
...". This sentence makes no recognition of the structure of national numbering 
plans, nor of the national legislation that governs their use and which have 
evolved to reflect different services and characte!
ristics. There is no concept of the difference between geographic and 
non-geographic, or fixed and mobile, and exposes a very naive understanding of 
the use of numbers. 

With regard to the potential list of sponsors, whilst certainly lengthy and 
impressive, does not include the global spread of these companies. One further 
consideration is that the nature of the application would appear to be better 
judged as a generic top-level domain name (gTLD). It is not clear what 
community of interest would be served by this application.

One point of confusion is understanding the value of including a list of 
attendees at the spring 2004 VON event in the application. It must not be 
implied that attendees at the Spring 2004 VON event support the application.
Comments on .Tel Telnic/Telname Application
The driver for this application would appear to be directory services. However 
in describing the issues associated with the application weaknesses become 
apparent. For example the assumption that the user will use their name as a 
means of getting the list of identifiers associated with a user is known. 

However there is no concept of multiple names being managed, e.g. John Smith. 
Significant issues in the application are those relating to governance and 
validation. Assuming that there is no relationship with the national numbering 
plan, and this is by no means clear (See below), then there appears to be no 
mechanism for ensuring that individuals have rights of use over the identities 
that they are registering. Such validation is required if "identity hijacking" 
is to be prevented.

The application refers to the concept of a Universal Communication Identifier. 
There is no reference to the work that has been completed within the European 
Telecommunications Standards Institute (ETSI), under the auspices eEurope on a 
topic of the same name. If the concept of UCI is different then this needs to 
be stated.

The application implies that existing and second level domain names are a 
barrier to growth of the Internet. This has not yet been proven. Independent of 
the domain name in use, clear rules are required to ensure the protection of 
the use of numbers that allow for conformance with national and international 
governance. 

There is a lack of clarity in the application. For example, section 4.4, second 
paragraph states that "The .Tel needs to be sponsored to ensure digits are 
restricted to maintain the integrity of a letters/words based Top Level Domain 
and to avoid interference with established or future national and international 
telephone numbering plans." This statement is not clear and assumes a 
relationship between .Tel and numbering plans that has not been fully explained.

The activity in relation to data protection and privacy issues is limited. With 
regard to "whois", asking for agreement is limited to being reactive. There 
appears to be no proactive process by which issues associated with data 
protection and privacy can be raised and sanctions employed.
Conclusion 
The issues associated with both applications for the .tel name are similar. 
These issues are explained below.

        *       Neither of the applications describes what specific community 
of interest would be served by having this TLD as a sponsored TLD. Rather the 
nature of the applications imply that a generic TLD would be the only 
appropriate solution

Irrespective of whether the TLD is sponsored or generic, the following issues 
need to be addressed and considered carefully as to how they will be solved in 
any implementation.

        *       Governance of .tel, needs to take into account the existence of 
global and national rules and conventions. Such governance should recognise the 
existence of the ITU and that, by international treaty, the ITU has the 
responsibility for the management of the global numbering scheme. It allocates 
the responsibility for administering the country codes to Countries and their 
national administrations. Such national administration is undertaken against a 
set of rules and legislation. Procedures exist within ENUM that recognise the 
above situation. Similar rules and procedures need to be created with regard to 
the use of .tel to ensure international and national rules are not violated, 
nor negative consequences are created.
        *       Additional procedures need to safeguard consumer interests. 
These procedures need to ensure that, assuming the governance rules have been 
addressed, only those individuals who have been allocated rights of use over 
numbers are those registering with .tel. Such procedures for 
authorisation/validation are to stop "hijacking" of numbers and identities. 
        *       It is important that inclusion of numbers has the agreement of 
those responsible for both the national and the individual aspects within the 
national numbering plan. This is needed to maintain its integrity and conform 
to data protection and privacy legislation. A similar need exists with regard 
to an individual's identity.
        *       With regard to data associated with individuals, it is 
important that the appropriate mechanisms are in place to meet national and 
regional data privacy rules and legislation that exist to protect consumer 
interests. Currently these significant issues are not addressed.

Before no further clarification is given to the above mentioned issues, ETNO 
can, at this point in time, neither support the .tel application from 
NetNumber/Pulver nor the .Tel application from Telnic/Telname.


End quotation

Best Regards

        Gerd Wiedenhaupt

        Chairman of the ETNO Working Group
        Naming, Addressing and Numbering Issues (NANI)

        T-Systems
        Systems Integration
        Naming, Addressing and Numbering, Technologiezentrum
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