Re: [EURO-Discuss] Proposed Euralo statement on the gTLD Applicant's guide
Hi Patrick, I am not sure about the end of the fifth paragraph:
We suggest that registries should be forced to use registrars only when their size goes beyond certain thresholds (e.g. 50k-100k domains).
Apart from that, I think this is a good EURALO statement and expresses our will as discussed. I am wondering if not at least the start - no further delay (!) to the new gTLD process - should be possible to enter the ALAC statement as well. It would certainly be in continuity of all previous ALAC statements. best greetings annette
-----Ursprüngliche Nachricht----- Von: "Patrick Vande Walle" <patrick@vande-walle.eu> Gesendet: 25.01.09 17:48:26 An: Discussion for At-Large Europe <euro-discuss@atlarge-lists.icann.org> Betreff: [EURO-Discuss] Proposed Euralo statement on the gTLD Applicant's guide
Dear colleagues,
Please find below and as an attachment, a draft Euralo statement on the gTLD Applicant's guide
Regarding the process: the public comments period is over. However, the ALAC is able to make comments directly to the board. The Euralo comments could be an appendix to the overall ALAC statement.
I have also included a draft ALAC statement. While the ALAC text may still change a bit in wording, I expect the main ideas to remain. Hence, I drafted the Euralo text to mention only the things that do not appear in the ALAC statement.
Please comment to the list,
Patrick
Euralo additional Statement regarding the First Draft of the Applicant Guidebook and Associated Document
The European At-Large Regional Organization supports the general ALAC statement below. Additionally, we nevertheless wish to insist on several aspects.
The EURALO does not support recent calls for a delay to the new gTLD process, we are particularly concerned about any delay to the introduction of IDN TLDs, both generic and country code and strongly oppose any further barriers to their introduction.
We also note that the process is conducted largely in English, and the complex and lengthy documentation that must be understood before making an application introduces a strong bias toward English speaking applicants. International competition will not be enhanced through processes that disadvantage the non-English speaking world.
Further, a rigid registry/registrar separation really does not fit into the reality of smaller applicants, especially non-profit. In these cases, the burden of having to cope with ICANN-accredited registrars might simply kill the registry, while registrars might have little interest in reselling or promoting the TLD.
Also, for TLDs aimed at specific geographically-defined communities, especially if the TLD is an IDN, there might be a serious scarcity of ICANN-accredited registrars offering services in that part of the globe, or there might even be none. We suggest that registries should be forced to use registrars only when their size goes beyond certain thresholds (e.g. 50k-100k domains).
The Euralo is also asking to have a different approval process for the geographical, community bounded, non-commercial, not-for-profit gTLD's. They should have the opportunity to enter their proposals with a low entry fee, which should be proportional to the intended size of the TLD (registry would pay extra fees once they grow and move from one size group to the following one).
ALAC Statement to the Board of ICANN on the First Draft of the Applicant Guidebook and Associated Documents - V1.
Firstly, the ALAC wishes to make clear that the At-Large community as a whole is not of one view with respect to many elements of the New gTLD programme. There are a number of members of our community who are sceptical of the need for new gTLDs at all â conversely, there are others who believe that new TLDs are a great thing and that the existing process has gone on much too long and should be expedited; between these views are various intermediary views.
However, with respect to the specifics in the Applicant Guidebook and associated documents, the community does have a number of strong views that are generally shared. They are as follows:
Firstly, with respect to the fee for a new TLD application, and the yearly fee for retaining the delegation, we find that the rationale is at best tenuous (for example, why is it that ICANN needs to recoup costs expensed in previous years for the new gTLD programme if it really doesnât wish to profit from the new TLD process?). More fundamentally, the one-size-fits all fee structure skews the entire programme in favour of developed world, for-profit TLDs and constitutes a major barrier to entry for community-based TLDs and developing world applications. This is not acceptable. The fee structure should encourage new types of TLDs and not just those wishing to try and create the ânext .comâ.
Secondly, while ICANNâs compliance processes are improving slowly, they are far from robust for the existing handful of TLDs; they are certainly inadequate for the hundreds of new TLDs that the applicant guidebook estimates will result from the first application round. We do not see that the new TLD process has learnt any lessons from past problems with respect to ongoing TLD operations â this must be remedied in a way that the ICANN community as a whole finds persuasive and comprehensive.
Thirdly, we do not find evidence that ICANN understands that new TLDs should be of benefit not just to the operator, but also to the public at large. The objective of ICANN is not simply to grow an ever-larger market for domain names â it is to provide a venue for administration of a global critical resource for the benefit of the global public. This concept is almost entirely absent from the current process. Where are the mechanisms to help ensure that unscrupulous or criminal elements cannot almost effortlessly continue the abuses of the TLD space in new TLDs that they have been doing in existing TLDs â abuses that are a continuing and growing concern worldwide?
Fourthly, the ALAC has made very clear our strong objections to so-called âmorality and public orderâ objections being any part of the new TLD process. ICANN is not an appropriate body to have any view on such matters, whether directly or indirectly. We find that the incomplete elements related to this are entirely insufficient and we call upon ICANN to make public all details related to its investigations to date with respect to this objection. It is very clear that what is in the guidebook is only a tiny part of what ICANN actually knows. Additionally, we find the idea that the International Chamber of Commerce would act as arbiter of these objections absurd. Until the entire process related to this objection is made clear, it is entirely inappropriate and irresponsible to be choosing a dispute resolution provider to handle them.
ALAC also believes that allowing a first TLD round to have hundreds of applications is completely irresponsible. This is a major new area of work for ICANN; the first round should be reserved for those applicants who can demonstrate that they have been working on their applications for a considerable time (of which there are quite a few). After that round is completed, the process can then be fine-tuned to implement the lessons learned so that subsequent rounds can allow many more applicants to be handled expeditiously and transparently.
Finally, we have seen no evidence whatever that ICANN has a plan to handle the massive amount of new work that this programme will create. Considering the problem that the organisation has executing on its existing responsibilities, we believe that a comprehensive resourcing plan for the New GTLD programme must be a part of the consultation process on the application processes themselves.
In closing, we wish to make clear that as an Advisory Committee to the Board, we expect not only to receive confirmation that the Board has received this Advisory, but to see evidence that the board has actually discussed the advice we have provided and a written response to make clear the Boardâs thinking on this issue. Indeed we believe that this is how advice from all Advisory Committees should be treated.
We thank you in advance for your thoughts on this communication and we are at your service if you have any questions regarding it.
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Hi Patrick and all, I support the motion of Annette that
(...) - no further delay (!) to the new gTLD process - should be possible (...)
Thanks and regards, Wolf Annette Muehlberg wrote Sun, 25 Jan 2009 22:38:
Hi Patrick,
I am not sure about the end of the fifth paragraph:
We suggest that registries should be forced to use registrars only when their size goes beyond certain thresholds (e.g. 50k-100k domains).
Apart from that, I think this is a good EURALO statement and expresses our will as discussed.
I am wondering if not at least the start - no further delay (!) to the new gTLD process - should be possible to enter the ALAC statement as well. It would certainly be in continuity of all previous ALAC statements.
best greetings annette
-----Ursprüngliche Nachricht----- Von: "Patrick Vande Walle" <patrick@vande-walle.eu> Gesendet: 25.01.09 17:48:26 An: Discussion for At-Large Europe <euro-discuss@atlarge-lists.icann.org> Betreff: [EURO-Discuss] Proposed Euralo statement on the gTLD Applicant's guide
Dear colleagues,
Please find below and as an attachment, a draft Euralo statement on the gTLD Applicant's guide
Regarding the process: the public comments period is over. However, the ALAC is able to make comments directly to the board. The Euralo comments could be an appendix to the overall ALAC statement.
I have also included a draft ALAC statement. While the ALAC text may still change a bit in wording, I expect the main ideas to remain. Hence, I drafted the Euralo text to mention only the things that do not appear in the ALAC statement.
Please comment to the list,
Patrick
Euralo additional Statement regarding the First Draft of the Applicant Guidebook and Associated Document
The European At-Large Regional Organization supports the general ALAC statement below. Additionally, we nevertheless wish to insist on several aspects.
The EURALO does not support recent calls for a delay to the new gTLD process, we are particularly concerned about any delay to the introduction of IDN TLDs, both generic and country code and strongly oppose any further barriers to their introduction.
We also note that the process is conducted largely in English, and the complex and lengthy documentation that must be understood before making an application introduces a strong bias toward English speaking applicants. International competition will not be enhanced through processes that disadvantage the non-English speaking world.
Further, a rigid registry/registrar separation really does not fit into the reality of smaller applicants, especially non-profit. In these cases, the burden of having to cope with ICANN-accredited registrars might simply kill the registry, while registrars might have little interest in reselling or promoting the TLD.
Also, for TLDs aimed at specific geographically-defined communities, especially if the TLD is an IDN, there might be a serious scarcity of ICANN-accredited registrars offering services in that part of the globe, or there might even be none. We suggest that registries should be forced to use registrars only when their size goes beyond certain thresholds (e.g. 50k-100k domains).
The Euralo is also asking to have a different approval process for the geographical, community bounded, non-commercial, not-for-profit gTLD's. They should have the opportunity to enter their proposals with a low entry fee, which should be proportional to the intended size of the TLD (registry would pay extra fees once they grow and move from one size group to the following one).
ALAC Statement to the Board of ICANN on the First Draft of the Applicant Guidebook and Associated Documents - V1.
Firstly, the ALAC wishes to make clear that the At-Large community as a whole is not of one view with respect to many elements of the New gTLD programme. There are a number of members of our community who are sceptical of the need for new gTLDs at all â conversely, there are others who believe that new TLDs are a great thing and that the existing process has gone on much too long and should be expedited; between these views are various intermediary views.
However, with respect to the specifics in the Applicant Guidebook and associated documents, the community does have a number of strong views that are generally shared. They are as follows:
Firstly, with respect to the fee for a new TLD application, and the yearly fee for retaining the delegation, we find that the rationale is at best tenuous (for example, why is it that ICANN needs to recoup costs expensed in previous years for the new gTLD programme if it really doesnât wish to profit from the new TLD process?). More fundamentally, the one-size-fits all fee structure skews the entire programme in favour of developed world, for-profit TLDs and constitutes a major barrier to entry for community-based TLDs and developing world applications. This is not acceptable. The fee structure should encourage new types of TLDs and not just those wishing to try and create the ânext .comâ.
Secondly, while ICANNâs compliance processes are improving slowly, they are far from robust for the existing handful of TLDs; they are certainly inadequate for the hundreds of new TLDs that the applicant guidebook estimates will result from the first application round. We do not see that the new TLD process has learnt any lessons from past problems with respect to ongoing TLD operations â this must be remedied in a way that the ICANN community as a whole finds persuasive and comprehensive.
Thirdly, we do not find evidence that ICANN understands that new TLDs should be of benefit not just to the operator, but also to the public at large. The objective of ICANN is not simply to grow an ever-larger market for domain names â it is to provide a venue for administration of a global critical resource for the benefit of the global public. This concept is almost entirely absent from the current process. Where are the mechanisms to help ensure that unscrupulous or criminal elements cannot almost effortlessly continue the abuses of the TLD space in new TLDs that they have been doing in existing TLDs â abuses that are a continuing and growing concern worldwide?
Fourthly, the ALAC has made very clear our strong objections to so-called âmorality and public orderâ objections being any part of the new TLD process. ICANN is not an appropriate body to have any view on such matters, whether directly or indirectly. We find that the incomplete elements related to this are entirely insufficient and we call upon ICANN to make public all details related to its investigations to date with respect to this objection. It is very clear that what is in the guidebook is only a tiny part of what ICANN actually knows. Additionally, we find the idea that the International Chamber of Commerce would act as arbiter of these objections absurd. Until the entire process related to this objection is made clear, it is entirely inappropriate and irresponsible to be choosing a dispute resolution provider to handle them.
ALAC also believes that allowing a first TLD round to have hundreds of applications is completely irresponsible. This is a major new area of work for ICANN; the first round should be reserved for those applicants who can demonstrate that they have been working on their applications for a considerable time (of which there are quite a few). After that round is completed, the process can then be fine-tuned to implement the lessons learned so that subsequent rounds can allow many more applicants to be handled expeditiously and transparently.
Finally, we have seen no evidence whatever that ICANN has a plan to handle the massive amount of new work that this programme will create. Considering the problem that the organisation has executing on its existing responsibilities, we believe that a comprehensive resourcing plan for the New GTLD programme must be a part of the consultation process on the application processes themselves.
In closing, we wish to make clear that as an Advisory Committee to the Board, we expect not only to receive confirmation that the Board has received this Advisory, but to see evidence that the board has actually discussed the advice we have provided and a written response to make clear the Boardâs thinking on this issue. Indeed we believe that this is how advice from all Advisory Committees should be treated.
We thank you in advance for your thoughts on this communication and we are at your service if you have any questions regarding it.
<hr> _______________________________________________ EURO-Discuss mailing list EURO-Discuss@atlarge-lists.icann.org http://atlarge-lists.icann.org/mailman/listinfo/euro-discuss_atlarge-lists.i...
Homepage for the region: http://www.euralo.org
--
_______________________________________________ EURO-Discuss mailing list EURO-Discuss@atlarge-lists.icann.org http://atlarge-lists.icann.org/mailman/listinfo/euro-discuss_atlarge-lists.i...
Homepage for the region: http://www.euralo.org
comunica-ch phone +41 79 204 83 87 Skype: Wolf-Ludwig www.comunica-ch.net Digitale Allemd http://blog.allmend.ch - EURALO https://st.icann.org/euralo/index.cgi?euralo_icann_at_large_europe
Hi Annette, Thanks for your kind words. On Sun, 25 Jan 2009 22:38:18 +0100, Annette Muehlberg <Annette.Muehlberg@web.de> wrote:
I am not sure about the end of the fifth paragraph:
We suggest that registries should be forced to use registrars only when their size goes beyond certain thresholds (e.g. 50k-100k domains).
This was taken from one of Vittorio's comments. The rationale is that small community-based TLDs may find it difficult to have registrars carry their TLD, which does not generate a lot of income but still a lot of hassle for the registrar. In the end, if no registrar carries those small TLDs, this will effectively kill them. I think it does make sense.
I am wondering if not at least the start - no further delay (!) to the new gTLD process - should be possible to enter the ALAC statement as well. It would certainly be in continuity of all previous ALAC statements.
This has already been raised, but faced opposition from many of our American colleagues. But I will hit the nail again. Regards, Patrick
Patrick Vande Walle ha scritto:
Hi Annette,
Thanks for your kind words.
On Sun, 25 Jan 2009 22:38:18 +0100, Annette Muehlberg <Annette.Muehlberg@web.de> wrote:
I am not sure about the end of the fifth paragraph:
We suggest that registries should be forced to use registrars only when their size goes beyond certain thresholds (e.g. 50k-100k domains).
This was taken from one of Vittorio's comments. The rationale is that small community-based TLDs may find it difficult to have registrars carry their TLD, which does not generate a lot of income but still a lot of hassle for the registrar. In the end, if no registrar carries those small TLDs, this will effectively kill them. I think it does make sense.
Also, that requirement may be a big problem for TLDs aimed at communities in the developing world - if you look at the list of ICANN-accredited registrars ( http://www.icann.org/en/registrars/accredited-list.html ) there are entire continents where you can find only one or two, if any at all - particularly Latin America and Africa. As a result, you may end up in the absurd but possible situation in which you have a TLD for which there is demand in certain communities, but since there is no accredited registrar interested in that "market" or willing to make business in those countries, you cannot find a registrar willing to sell the domains. Ciao, -- vb. Vittorio Bertola - vb [a] bertola.eu <-------- --------> finally with a new website at http://bertola.eu/ <--------
Patrick Vande Walle ha scritto:
Hi Annette,
Thanks for your kind words.
On Sun, 25 Jan 2009 22:38:18 +0100, Annette Muehlberg <Annette.Muehlberg@web.de> wrote:
I am not sure about the end of the fifth paragraph:
We suggest that registries should be forced to use registrars only when their size goes beyond certain thresholds (e.g. 50k-100k domains).
This was taken from one of Vittorio's comments. The rationale is that small community-based TLDs may find it difficult to have registrars carry their TLD, which does not generate a lot of income but still a lot of hassle for the registrar. In the end, if no registrar carries those small TLDs, this will effectively kill them. I think it does make sense.
Also, that requirement may be a big problem for TLDs aimed at communities in the developing world - if you look at the list of ICANN-accredited registrars ( http://www.icann.org/en/registrars/accredited-list.html ) there are entire continents where you can find only one or two, if any at all - particularly Latin America and Africa. As a result, you may end up in the absurd but possible situation in which you have a TLD for which there is demand in certain communities, but since there is no accredited registrar interested in that "market" or willing to make business in those countries, you cannot find a registrar willing to sell the domains.
You're right. But what's the answer in terms of a recommended policy? Such new registries should not be required to use ICANN accredited registrars, and may opt out based on market conditions of their region or depending on the target market, or may themselves act as registrar? Adam
Ciao, -- vb. Vittorio Bertola - vb [a] bertola.eu <-------- --------> finally with a new website at http://bertola.eu/ <--------
_______________________________________________ EURO-Discuss mailing list EURO-Discuss@atlarge-lists.icann.org http://atlarge-lists.icann.org/mailman/listinfo/euro-discuss_atlarge-lists.i...
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Adam Peake ha scritto:
You're right.
But what's the answer in terms of a recommended policy?
Such new registries should not be required to use ICANN accredited registrars, and may opt out based on market conditions of their region or depending on the target market, or may themselves act as registrar?
In the proposal I posted a couple of months ago (if I remember well the details), registries wouldn't be required to use registrars until they get to a certain number of registrations (eg 100'000) and at least three accredited registrars express interest in selling their TLD. Once both conditions are met, the use of registrars is compulsory. Ciao, -- vb. Vittorio Bertola - vb [a] bertola.eu <-------- --------> finally with a new website at http://bertola.eu/ <--------
At 15:02 27/01/2009, Vittorio Bertola wrote:
Once both conditions are met, the use of registrars is compulsory. Ciao,
What is the advantage to the users - if they are happy with no registrar, why do youi want to impose registrars onto them, their procedure, etc. Not to be bothered by a registrar is a quality feature users tend to appreciate. As well as no-whois etc. Diversity in the offer is fostering competition, otherwise competition is only on prices and not on quality. jfc
participants (6)
-
Adam Peake -
Annette Muehlberg -
JFC Morfin -
Patrick Vande Walle -
Vittorio Bertola -
Wolf Ludwig