Comment on gTLD Recommendation

["Ray Fassett" <ray@xxxxxxxxxxx>]

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I would like to commend Dr. Lynn on a very thoughtful document that I
believe articulates many of the complexities of expansion at the Top Level
of DNS as I believe these to be.  This is a document that covers a lot of
ground.  I would like to focus this specific comment on the recommendation
to the Board to move forward, in limited fashion, of only the sponsored TLD
model.

The recommendation to the Board to consider the option of parallel
processing strictly for the sponsored TLD model is, in part, premised upon
the fact that a rather factual study and evaluation can be performed in a
reasonable period of time (30 to 60 days) that address the various risk
factors inherent with the sponsored TLD (as this is defined in the
document).  While I believe this to be a true statement, it is also
noteworthy that Dr. Lynn finds support that both the sponsored TLD model
and the unsponsored TLD model - on a limited scale - pose nearly the same
if not identical risk to the technical stability of the root server
structure.  I cite the following comment by Dr. Lynn contained within the
document:

"It is hard to find anyone who would argue that tens or perhaps even
hundreds of new small- to medium-sized gTLDs could not be safely added..."

While there are issues that require further study and evaluation for both
the sponsored and unsponsored model, the issue of technical stability upon
the root server structure does not appear, from this document and above
quote, to be a material reason to exclude the unsponsored model from the
recommendation of a limited system of parallel processing.  That, in fact,
there are other, more overriding concerns, that require more time and
resources relative to the unsponsored model (as identified by the NTEPPTF
as their critical areas of study) that cause the removal of the uTLD from
the system of parallel processing and corresponding recommendation of this
document to the Board.

I believe this document authored by Dr. Lynn states well why the sponsored
TLD can move forward in limited way.  I believe it is important, however,
for reasons of greater clarity to articulate whether the issue of technical
stability to the root server structure is - or is not - a material reason
for the exclusion of the unsponsored model from this recommendation.  In
reading this document, the answer appears to be that effects upon root
server structure and stability is not a material reason to exclude the
unsponsored TLD from the recommendation, given the parallel process is
limited in scope.  That there are other issues inherent with the
unsponsored model that in fact cause such exclusion and requirement of
further study (critical study as recommended by the NTEPPTF).  Greater
clarity is needed specific to the single issue of whether effects upon root
server structure and stability is, on its own merit, a material reason for
the exclusion of the uTLD from the recommendation to the Board of a limited
round of expansion in parallel.

Along these lines, the third model of the first round expansion process in
2000, being the restricted TLD, is not at all discussed and I believe a
weakness in the overall presentation and recommendation.  The option of
including the restricted TLD (an example being .BIZ) as part of this
recommendation - seems completely ignored for some unknown reason.  In
other words, what are the issues that require further evaluation and study
that exist with the restricted TLD model that do not exist with the
sponsored model?  These are not identified by the document, but perhaps
implied by the assumption that if not an sTLD, then it must be a gTLD.  I
believe, for the Board to consider the recommendation, that this is an
invalid assumption without further discussion and eventual explanation.

Further, is it possible that a review of the restricted model can be
performed in a like-kind time frame (i.e. 30 to 60 days) as is being stated
of the sponsored model (and a key reason as to why the sponsored model can,
as stated, move forard in parallel)?  This question is not addressed for
consideration by the Board.  Is it to be assumed by the Board (and the
community) that issues of moving forward in parallel that would include the
restricted TLD model are the very same as that of an unsponsored TLD?  This
is not addressed for Board consideration, relative to the recommendation of
limited expansion in parallel.  Consistent with Paragraph II.C 8 of the new
MoU with the U.S. Department of Commerce (as is also cited by Dr. Lynn), I
believe that exclusion of the restrictive model needs to be fully
articulated consistent with the wording contained within this MoU as
follows:

"including public explanation of the process, selection criteria, and the
rationale for selection decisions."

The recommendation as proposed of moving forward in parallel in a limited
fashion fails, to me, to address for the Board and the community
the "rationale" of the exclusion of the restricted model.  If nothing else,
it needs to be articulated that a study of the restricted model cannot be
performed in a like-kind time frame as is being stated as possible for the
sponsored model that allows the latter to be recommended to move forward in
parallel.

I am formally requesting, for reasons stated, for proper discussion and
explanation of whether the restricted model can be included as part of the
recommendation of moving forward in a limited fashion and in parallel as
has been recommended for the sponsored model by this document.  I believe
his request to be consistent with the criteria as set forth in Paragraph
II.C 8 of the MoU, as cited previous. The "rationale" for excluding the
restricted model from the recommendation needs, in my view, to be properly
articulated to the Board and to the community.

Thank you for your consideration.

Ray Fassett