[ccnso-idncctld] IDNccTLD Draft Final Report - Comments from France
Dear all, Apologies for these late comments. There are two major points I would like to make suggestions on. The second one tries to explore a possible solution regarding the "objection procedure" and proposes a formulation for an additional Guiding Principle. *1. Clearer distinction between string selection and delegation* The current draft report is very detailed and good. However, upon closer reading I found a discrepancy within it regarding one specific element : the distinction between the string selection and the delegation itself. ** Recommendation 2 in the end clearly indicates that : *- the first stage concludes when a string and language table are clearly defined - the second stage concludes with "the publication of the selected string on the ICANN website" * Indeed, neither the string selection nor the due diligence process on the string and language tables require the existence of an already designated manager. Still, the whole section regarding string selection currently requires that the application be made by the "selected delegate", even as the designation of the IDN ccTLD manager is indicated as step 5 in the "preparation within the territory", which clearly indicates that it can be the last action undertaken by the territory's authorities. This in my view penalizes the countries that already have devoted a lot of efforts in the initial stages and may well finalize the designation of their ccTLD operator in the time required for the due diligence on the string. The parts related to the delegation itself in the draft are limited basically to : it is up to the authorities to select the manager and the delegation follows the normal procedures of IANA. So there is clearly a difference and most of the IDN ccTLD process actually refers to the string selection. In order to alleviate the above incoherence within the document, it would be preferable to more clearly separate the two processes : the string selection and the delegation itself. This would actually be in full accordance with the paragraph at the very beginning of the report that states in no ambiguous terms : *As determined in the Initial and Interim Report, the Fast Track requires two specific mechanisms: 1. A mechanism for the selection of the IDN ccTLD string; and 2. A mechanism to designate an IDN ccTLD manager.* To be honest, I even could go as far as considering that the fast track is mainly devoted to the selection of the string. The delegation process could actually be mentioned only as : according to existing IANA rules for delegation (both in the choice of the delegate and the delegation process itself). This clearer distinction has strong political benefits, allowing territories to formally enter the fast track rapidly, and it requires only minor modifications to the present draft (mostly by replacing the expression "selected delegate" by "applicant" in the string selection phase). *A version with corresponding track changes is attached to this mail.* This is something that I tried to convey in some of the earlier discussions, but probably did not express myself correctly. I hope this will seem appropriate and an improvement by other members. *2. Handling of comments (ie addressing "objections")* As I have mentioned in previous mails, a formal objection procedure would only encourage objections. At the same time, putting on the ICANN board only the responsibility of managing potential objections will make them more publicly visible, at a later stage and harder to solve. It could also be understandably resented by some territories. The objective we should pursue in the present recommendations is therefore to encourage resolution of possible problems (and we know there will be some) at the lowest level possible. In order to avoid the insertion of minority views (due to one specific case we all have in mind), could we try to place this more generally under the category of any problem arising within a community of territories that intend to submit a string in the same script (cyrillic, arabic, chinese, etc...) ? In such a case, I think we agree that any problem arising among those countries regarding their choice of string should be first and foremost addressed between them. I understand this is the approach that countries using arabic script have undertaken already with the Arab League group they have instituted. A coordination among territories using a common script will be useful anyway in the future and there is a benefit to encourage it early on. An simple encouragement to hold consultations prior to submitting a string application would not infringe on the responsibilities of the territory and would provide additional information to the Board should the problems persist. Just as the current report encourages "territories using the same script" to coordinate their language tables, it is proposed to insert an additional Guiding principle provision that could for instance read as follows : *"H. Coordination among territories using the same script Territories using the same script should hold consultations to address any issue regarding their string selection prior to submitting their application to the fast track process" * This is of course only a basis for discussion and the formulation can certainly be improved. Guiding Principle E in that context would remain as is. I hope this proposal can help the discussion move forward and help us avoid the insertion of "minority views" introducing a formal objection procedure that would probably raise more issues than it would solve. Apologies again for the late posting. Best Bertrand P.S. Final Note : I leave aside in this mail the possible problems between two script spaces; for instance if a string in an IDN script is confusingly similar (in particular visually) to another existing string in ASCII (the case might arise with cyrillic, if Russia were to apply for .py (.ru in Cyrillic, which is visually identical to the ccTLD string for Paraguay). I understand that this has not been proposed by the Russian Federation, but a comment has been posted on that very point on the Icann comments site regarding IDNs (see : http://forum.icann.org/lists/idn-cctld-issues/msg00004.html)<http://forum.icann.org/lists/idn-cctld-issues/msg00004.html%29> Such problems are clearly within the remit of the language committee, whose composition is precisely appropriate to handle these trans-script questions. It could be explicitely mentioned in the mandate of this committee. -- ____________________ Bertrand de La Chapelle Délégué Spécial pour la Société de l'Information / Special Envoy for the Information Society Ministère des Affaires Etrangères et Européennes/ French Ministry of Foreign and European Affairs Tel : +33 (0)6 11 88 33 32 "Le plus beau métier des hommes, c'est d'unir les hommes" Antoine de Saint Exupéry ("there is no greater mission for humans than uniting humans") Attachment:
Draft Recommendations IDNCWG version 1 comments France.doc
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