Comments on .aero Renewal Proposal
This renewal proposal requests modification of the registry agreement to allow the registry to develop alternative distribution channels outside of the regular registrar accreditation policy and to allow SITA to deal directly with the registrants.
This is a puzzling request in that the registry operator is free to undertake the development of any distribution channels it wishes to within the bounds of the current registrar accreditation policy. Specialized distribution is necessary to deliver different services to different market segments - but this does not mean that registrar accreditation policies should be waived. The original registrar accreditation policy was implemented to ensure not only a competitive environment as the registry operator points out, but also to ensure a stable, predictable and secure environment that met the requirements set out by the Internet community, the White Paper and ICANN's policy development process. SITA has incorrectly assessed accredited registrars as a homogeneous distribution channel leading to an assumption that the current service failures are related to the distribution channel being used. Given that any organization that qualifies may become accredited to act as a registrar, it also stands to reason that organizations with the skills SITA views as necessary for distribution of .aero registrations could become accredited.
SITA should be encouraged to develop a specialized distribution channel - one that will presumably see new specialized registrars become accredited in order that they meet the technical, financial and operational requirements set forth by ICANN. but ICANN's implementation of the Registrar Accreditation policy in this sponsored TLD agreement should not be changed.
Regarding SITA's request to deal with the public directly, this request should be granted, provided that SITA create and implement plans to ensure that the obvious internal conflicts of interest are avoided and that the registry can provide equal access to all registrars, including its own, without favoring any specific one (especially its own).
On behalf of Tucows Inc.,