Compulsory DNSSEC and 99.9% availability of the Registration Data Publication Service (RDPS) and the EPP service are uneconomical technical requirements

[Stefan Legner <sl@xxxxxxxx>]

Dear ICANN staff,

thank you for your efforts in bringing this process forward and finding 
a well working balance between the many and often contradicting 
requirements of the community.
From a technical standpoint, I have noticed two severe technical 
modifications in version 3 of the draft applicant guide book and the 
draft new gTLD agreement, which seem to unnecessarily limit the 
competition on the TLD and registry market.
DNSSEC:
As stated in version two of the guide book, DNSSEC should be an optional 
feature of a registry. Offering DNSSEC might be a unique and important 
selling proposition for one TLD and its domains. For other TLDs it might 
be an unnecessary driver of costs. It should be left within the general 
responsibility of a TLD-owner whether and when this feature is 
introduced and thus fosters the competition amongst TLDs.
Availability of RDPS and EPP service:
The tightened requirements of 99.9% availability for RDPS and EPP 
services including all planned outages seem to go far beyond  the 
practical requirements of some potential new gTLDs. I propose that the 
requirements are reduced to the 99% value as stated in version two of 
the draft new gTLD agreement.
99.9% availability of a multi level technical infrastructure including 
planned outages require complex system architectures and operational 
processes which significantly increase the infrastructural costs. Some 
new TLDs might want a nearly 100% availability of the RDPS and the EPP 
system, require it from their technical operators and pay the price. For 
others, the actual requirements might impose unnecessary costs. Reducing 
the minimum requirements to 99% will leave responsibility with the 
TLD-owner and thus again foster the competition amongst TLDs and 
registry service providers.
Sincerely

Stefan Legner
SLcon
IT & Management Consulting
Germany