Here a some of my thoughts in response to this letter as well as some suggested action items that I think should be done in the next few days.
First of all, I compliment the ccNSO on a well articulated letter with what seems to me to be a constructive tone. Second, I suggest that Avri officially support the recommendation for a joint ccNSO/GNSO meeting in New Delhi, an idea that I believe she has already indicated support for. Third, I recommend that we use the time we have between now and New Delhi to carefully prepare for the proposed joint ccNSO/GNSO meeting in New Delhi. Regarding the latter:
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I believe that completion of the GNSO response to the ccNSO/GAC Issues Paper on IDN ccTLDs is a key step. Ideally it would have been good to accomplish that before the end of the ccNSO public comment period on their IDN ccTLD PDP (25 January). Because that is not feasible before the New Delhi meetings, I suggest that, before 25 January, Avri send a letter to the ccNSO and to their comment site informing them that our response (as requested by the Board) will not be completed until New Delhi and we respectfully request that our input be considered in the PDP. [Note that we would need to act on this before the end of this current week so we will have to decide whether or not to do this via our list.]
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I do not think that it will be effective to engage in discussion with the ccNSO regarding the issues we are concerned about prior to the joint meeting in New Delhi. In my opinion, the chances are too high that there will be misunderstanding and even miscommunication until both Councils are face to face and that can cause more harm to the success of the joint meeting than good.
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As a means of getting our preparation for the joint meeting started, I identify the following points from the ccNSO letter to the Board for which I believe we need to prepare: 1) The ccNSO clearly believes that the issues we raised will take much longer than 120 days; 2) they appear to assume that it is possible to introduce fast tract IDN ccTLDs before any resolution of the issues we raised; 3) they state that as far as the issues relate to IDN ccTLDs, they should be the responsibility of the ccNSO; 4) they also believe that they must be dealt with in a PDP. I provide my preliminary thinking about each of these below.
1) The ccNSO clearly believes that the issues we raised will take much longer than 120 days.
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The original intent of the 120 day target was to attempt to avoid any further delays in the implementation of IDN TLDs (gTLDs or cc fast track IDN TLDs).
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I believe that the goal of avoiding further delays remains valid and if the 120 day target is unrealistic, then it is important to begin work on the issues we raised as soon as possible with the goal of at least agreeing to some interim approach until full resolution of the issues can be completed.
2) They appear to assume that it is possible to introduce fast tract IDN ccTLDs before any resolution of the issues we raised.
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I believe that this may be a fundamental difference of opinion between the GNSO and ccNSO but not one that necessarily needs to be a show stopper. I think it is less important for the two SO's to come to agreement on the assumption than it is to jointly develop an interim approach as suggested in the previous item.
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I don't think we should spend a lot of time trying to convince them that a final policy for allocating new TLDs into GNSO and ccNSO name space has to happen before any IDN TLDs are introduced, but instead we should work together to come up with a way that our concerns can be addressed in the short term. I Therefore, I recommend that we focus our attention on coming up with some ways forward on this that satisfy our needs with regard to TLD allocation and still allow the ccNSO to deal with the bigger policy issues over a longer period of time.
3) They state that as far as the issues relate to IDN ccTLDs, they should be the responsibility of the ccNSO.
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This is a point where I believe there is gap in understanding between the GNSO and ccNSO or at least there does not seem to be an recognition of a key point we tried to make: allocation of new TLDs into the DNS is an issue that affects both SO's and therefore must be worked by both SO's.
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This is an area that I think deserves caution because I think it would be counterproductive for us to give the impression that the GNSO wants to determine policy for the ccNSO so we should make it clear from the outset that that is not our intent.
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This is a place where an example might be helpful. Consider the case of .berlin. Should that be a GNSO or a ccNSO. It appears to me at a minimum that guidelines need to be in place before .berlin is introduce that determine what SO has policy responsibility. And any such guidelines need to be developed by both SO's because both SO's are impacted.
4) They believe that the issues the GNSO raised must be dealt with in a PDP.
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If this is the case, which PDP process should be used? the GNSO PDP or the ccNSO PDP? It may not matter too much provided that the PDP used allows for full participation by the other SO with regard to the TLD allocation issue.
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At present, there is not a joint PDP process in the ICANN Bylaws; maybe this is an idea for further development.
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The idea of a less formal joint working group was made to facilitate a timely response to the issues. In my opinion, waiting two years for a ccNSO PDP process doesn't work, at least not for the development of an interim approach to the broader TLD allocation issues. This seems to be a key area where the two SO's need to focus attention.
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In the meantime, I am confident that we can work together with the ccNSO. From what I have observed so far, the ccNSO is heading in a direction that is not far off from what we could support. In the draft issues report that the IDNC is considering, one idea under consideration for IDN ccTLD string selection is this: "the string must be a meaningful representation of the name of the Territory or an abbreviation of the name of the Territory in the relevant script". Please note that this is not a final position. But if it is adopted it provides some defined limitations in terms of IDN ccTLDs and could possibly even be used in developing interim guidelines for allocation of TLDs into the two policy name spaces.o
Finally, I have concerns about the following statement in the next to last paragraph of the ccNSO letter to the Board: "During the process the delegation of new TLDs would need to be suspended to ensure that TLDs are not created in circumstances that would be a breach of the policy being developed." I think we need to get clarification of this in the proposed joint meeting. Considering that the ccNSO PDP is estimated to take at least two years, this could easily be a way of delaying IDN gTLDs, depending on what it means. I am not suggesting that it was intended that way but I definitely think we need to get clarity in that regard.
In conclusion, I am proposing the following action times, the first two of which need to happen in the next four days (NLT 25 Jan.):
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Avri send a letter to Chris Dispain officially supporting the recommendation for a joint ccNSO/GNSO meeting in New Delhi.
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Avri send a letter to the ccNSO and to their comment site informing them that our response to the ccNSO/GAC Issues Paper on IDN ccTLDs (as requested by the Board) will not be completed until New Delhi and we respectfully request that our input be considered in the PDP.
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We initiate a planning process for the joint meeting in New Delhi ASAP.
To facilitate moving forward on the above so that we can meet the time constraints, please comment on the Council list right away.
Chuck
Forwarded with permission a.
Begin forwarded message:
From: "Chris Disspain"
Date: 21 January 2008 12:11:37 GMT+01:00
Subject: ccNSO response to GNSO resolution
Peter and Paul,
Attached is the ccNSO response to the GNSO resolution of 3 January 2008. Please forward this letter to the ICANN Board list at your earliest convenience.
Pursuant to the letter I shall be formally writing to Avri Doria tomorrow to invite the GNSO to a joint meeting in New Delhi.
Kind Regards,
Chris Disspain
CEO - auDA
Australia's Domain Name Administrator
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