Comments on the Preliminary Evaluation Report

[Bret Fausett <fausett@xxxxxxxxxxx>]

Title: Comments on the Preliminary Evaluation Report

Disclaimer: I consulted on one of the .org proposals, but I submit these comments as an individual. 

Comments on the Preliminary Evaluation Report.

  (1) I was disappointed that the Preliminary Evaluation Report recommended a single bid rather than forwarding the names of a tier of acceptable registry applicants to the Board. The Gartner Group, for example, recommended that any one of five bidders would be able to operate the .org registry competently. This was also the approach taken in the General Counsel's report. Each of the evaluators, in fact, had distinct groupings of candidates that, often, were closely bunched in their scoring. In my opinion, the numerical distinctions in each of the reports were not significant enough to warrant picking a “winner.” When the Final Staff Report is submitted to the Board, I would recommend that it be revised to follow a tiered approach, including the names of each of the several registries technically and legally competent to succeed Verisign. 

  (2) Both the Preliminary Staff Report and the press release that accompanied it referenced selecting the ISOC proposal and even selecting "Internet Society (ISOC) as the successor registry operator for the .org registry." According to its application, however, ISOC will not be the successor registry -- ISOC proposes to create a new non-profit corporation, the "Public Interest Registry," if its application is successful. As I read the ISOC application, the "PIR" does not yet exist. It has no Staff and no Board of Directors. It has no contract with its chosen service provider (though ISOC has signed a cursory letter of intent with Afilias). In tentatively selecting the ISOC bid, the Preliminary Staff Report badly underestimates the value of:

• PIR staff to begin and oversee the transition process in preparation for a migration of the .org TLD away from Verisign;
• PIR staff to oversee the chosen service provider both in the transition period and thereafter;
• A Board of Directors for the non-profit registry, willing and able to serve;
• Bylaws and Articles of Incorporation that would provide a governance structure for the PIR’s activities;
• The identity of the people selected to serve as PIR’s staff and on its Board of Directors.
  

Perhaps the last point is the most important. Other non-profit applicants went to great lengths to find capable, committed individuals willing to do the hard work of transitioning the .org registry to a new provider and then serving the .org registrant community. PIR may well find equally capable individuals to serve on its staff and Board, but the effective and stable operation of the .org TLD is too important to take the completion of these critical tasks on faith. The importance of having already made these personnel decisions is heightened by the short time in which to complete the transition. 

Thank you for the opportunity to comment on this work in progress.

Very truly yours,

Bret A. Fausett
http://www.lextext.com