Feedback from Nominet UK
- To: strategic-plan-comments@xxxxxxxxx
- Subject: Feedback from Nominet UK
- From: Lesley Cowley <lesley.cowley@xxxxxxxxxxxxxx>
- Date: Wed, 9 Feb 2005 09:01:23 +0000
Nominet UK, the country code Top Level Domain registry for .uk, thanks
ICANN for the opportunity to comment on the ICANN Strategic Plan 2003-04
We fully recognise that it will have been a major piece of work and no
easy task to produce the Plan and to develop the strategic priorities
contained within it. In our experience, it can be challenging to develop
strategic plans that balance the sometimes conflicting needs of a large
range of stakeholders, during a period of rapid external and internal
change. The publication of the Plan will assist in establishing dialogue
between stakeholders and ICANN and will also assist in establishing
priorities. Our feedback on the Plan should therefore be set in this
context and is intended to be constructively supportive. We have resisted
the temptation to make overly detailed comment, but would be happy to
amplify on any area should this be considered helpful.
1. General Strategic Plan Content
Much of the content of the Plan details ICANN?s achievements to date and
?Where we are now?. This will be informative for stakeholders new to ICANN
and is helpful in setting the background to the strategic plan. However,
the areas detailing ?Where we are going? and ?How and when we are going to
get there? are comparatively less developed and detailed. Given the nature
and extent of some of the proposed developments, it would perhaps be
helpful to develop these aspects of the Plan further.
In particular, we would suggest the full allocation of projects or
initiatives to particular years of the Plan period and the identification
of priorities and progress milestones. The further development of these
aspects would then assist ICANN staff with the setting and management of
stakeholder expectations, the development of a project programme, the
development of the financial strategy and the budget process.
2. Strategic Priorities
The mission of ICANN stresses its role in ensuring the stable and secure
operation of the Internet?s unique identifier systems and strategic
priority one is identified in the Plan as stability and security. It is
not clear whether the priorities are in order of importance. Nominet
believes that this is the most crucial of ICANN?s strategic priorities and
should be identified as such.
The stability and security section of the Plan also appears to be
relatively light in contrast to the other strategic priorities. We assume
that this is because the focus is on strengthening what is already in
place, but would suggest that assessment of the size of the ?gap? between
the current and desired positions for each of the priorities would help
stakeholders better understand the strategic plans.
With regard to strategic priority two, it needs to be made clearer that
the development and management of initiatives that foster competition and
consumer choice, whilst supporting compliance with existing policies and
contracts, applies only to the gTLD market. For the ccTLDs, competition
and consumer choice at registrar level is a responsibility of the
respective governments, registries and local Internet communities.
3. Financial Strategy
The need to develop and implement a financial strategy is identified
within the plan, but it is not clear when or how this will be developed
and what changes to the Plan may need to be contemplated if ICANN?s income
exceeds projections, does not meet projections or if costs, such as those
related to litigation, increase significantly.
Given that the ICANN funding requirement is projected to increase by 165%
during the life of the Plan and that diversification of income sources may
well take some time to develop, it would be helpful to develop the
financial strategy at an early stage. We would recommend from experience
that this should include the development of multiple scenarios, varying
some of the key assumptions that will affect finances, such as the stated
assumption that overall domain growth will continue at 15% per annum. It
should also be acknowledged by all ICANN stakeholders that the Plan may
need to be iterated several times, depending on income levels.
It might also be possible to develop partnerships with other members of
the Internet community to reduce costs, for example, to assist with the
provision of accommodation to establish an ICANN presence in each ICANN
region. In turn, this may also provide the benefits of building closer
relationships and mutual understanding with members of the Internet
4. Communications Strategy
The need to develop and implement a communications strategy is identified
within the plan, but it is not clear when or how this will be developed.
It is suggested that this should be developed as early as possible during
the Plan period, particularly as the cost of the comprehensive and
multilingual strategy that is being proposed may perhaps have been
difficult to estimate at this stage.
It may also be possible to develop partnerships with other members of the
Internet community to reduce communication costs, for example by using
existing regional and local mechanisms and fora. In turn, this may also
provide the benefits of building closer relationships and mutual
understanding with members of the Internet community.
5. Human Resources Strategy
The need to develop and implement a Human Resources strategy does not
appear to have been identified within the plan, and it is not clear
whether such a strategy already exists. Given that the number of ICANN
staff is forecasted to increase by 50 (167%) over current numbers during
the Plan period and that some staff will be based internationally, it is
suggested that if there is not an existing strategy, this should be
developed at an early stage in order to attract, train and retain talented
and able staff. Nominet speaks with some experience of this issue, having
experienced similar percentage changes in staffing in response to market
It should also be recognised that the recruitment and training of this
number of staff within the suggested time period will be challenging and
may have a considerable impact on the ability of the management team to
implement the many new projects that will be likely to result from the
agreement of the Plan. Indeed, in our own experience, management and staff
capacity rather than capability can often become an issue.
6. Uniform Dispute Resolution Policy (UDRP)
We note that there appears not to be any reference to the updating of the
UDRP in the Plan, which may well be disappointing to the Intellectual
Property community and to registrants covered by the UDRP. As you may be
aware, Nominet runs a Dispute Resolution Service for .uk domain name
disputes, which has recently been revised for the second time since its
inception, in response to Local Internet Community feedback.
Nominet welcomes the proposals to strengthen the core IANA services and to
improve support services for those that use IANA. The IANA function is of
crucial importance to Nominet, other ccTLDs and the gTLDs and so it is
hoped that these proposals will be implemented during the early years of
the plan. Nominet would be happy to offer our experience and assistance in
developing the more detailed vision and implementation plans that will
need to follow in order to realise these proposals.
8. ccTLD Participation in ICANN
We note that the Plan reports that ccTLD managers participate through the
ccNSO in ICANN?s policy development process. However, the ccNSO is still
at an early stage. Given that only 17% of ccTLDs have joined the ccNSO to
date and this number includes a disproportionate number of small ccTLDs,
this statement should perhaps be more properly expressed as an aspiration.
We acknowledge and appreciate the fact that ICANN is currently seeking to
address this issue and has been responsive to our suggestion that ccNSO
reform offers a way forward, but this may take some time. Therefore,
whilst the ccNSO is in a formative stage, the Plan should identify as a
priority mechanisms for the continuation of constructive dialogue and
liaison with the members of the ccTLD community who have not joined the
ccNSO during the period of the plan, such as via the CENTR organisation.
9. ccTLD Funding of ICANN
We note the Plan expectation that the ccTLD community will collaborate
through the ccNSO to devise a methodology for its ICANN contributions.
However, given the low membership of the ccNSO at this formative stage,
the Plan may also need to include other mechanisms for dialogue with the
83% of ccTLDs who are currently not members of the ccNSO, particularly as
a 33% contribution increase is projected in the first year of the Plan.
It is assumed that the recommendation of the 1999 Task Force on Funding,
which suggested that ccTLDs contribute a 35% share of ICANN?s continuing
revenue requirements, will be reviewed as part of the development of the
funding methodology. As you will be aware, Nominet and many other ccTLDs
feel that they should not be required to resource activities that do not
concern them such as fostering gTLD competition, registrar compliance and
gTLD registrant support. Neither do we feel that we should be required to
fund activities that are already funded by us at a Local Internet
Community level such as dispute resolution, local policy development and
We note that revised Governmental Advisory Committee principles have been
published since the Plan was first drafted, which will need to be taken
into account when iterating the Plan. We agree with the stated GAC main
principle of subsidiarity and that ccTLD policy should be set locally,
unless it can be shown that the issue has global impact and needs to be
resolved in an international framework.
Like many ccTLDs, Nominet already funds a policy development process that
seeks to involve all relevant local stakeholders. Nominet and the UK Local
Internet Community therefore remain strongly against any form of domain
name transaction or billable event based fee.
However, Nominet stands ready to fund our fair share of IANA and ICANN
services that are directly relevant to ccTLDs.
I do hope that this feedback will be of use to you as you further develop
and implement the Plan. Nominet endorses the coordination, collaboration
and cooperation approach that is now being taken by ICANN and thanks ICANN
for the opportunity to comment on its Strategic Plan.
Lesley Cowley (Mrs.)