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 – 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 doesn’t 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 “next .com”. Secondly, while ICANN’s 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 – 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 – 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 – abuses that are a continuing and growing concern worldwide? Fourthly, the ALAC has made very clear our strong objections to so-called “morality and public order” 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 Board’s 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.
Thanks a lot, Patrick, for all your efforts on this EURALO statemement -- what I find consistent and I fully support. Best, Wolf Patrick Vande Walle wrote Sun, 25 Jan 2009 17:47:
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 – 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 doesn’t 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 “next .com”.
Secondly, while ICANN’s 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 – 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 – 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 – abuses that are a continuing and growing concern worldwide?
Fourthly, the ALAC has made very clear our strong objections to so-called “morality and public order” 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 Board’s 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.
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
Hello, Thanks to Patrick, Adam and others for pushing this forward. Appending regional comments to the ALAC statement seems like a good idea. I wonder though about the key sentence, "EURALO does not support recent calls for a delay to the new gTLD process." I'm not clear on how this conclusion fits with the laundry list of concerns raised in both the EURALO and ALAC texts. Together, they say we want ICANN to rethink registry/registrar separations; amend the guide's requirements regarding the use of registrars; have a different approval process for geographical, community bounded, non-commercial, not-for-profit gTLDs; change the one-size-fits all fee structure; improve compliance processes; build in public interest oriented mechanisms; get rid of MAPO objections; drop ICC arbitration; change the number of applications contemplated in the first round; and develop a comprehensive resourcing plan for the new gTLD program. How could addressing all these concerns not involve delays in the process? Can we really have it both ways? Would we be happy if the board cited the "no delays" headline conclusion as support for moving forward, but then didn't address fully the concerns raised? Is that a far-fetched scenario? Just wondering, Bill On Jan 25, 2009, at 5:47 PM, Patrick Vande Walle wrote:
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 – 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 doesn’t 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 “next .com”.
Secondly, while ICANN’s 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 – 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 – 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 – abuses that are a continuing and growing concern worldwide?
Fourthly, the ALAC has made very clear our strong objections to so-called “morality and public order” 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 Board’s 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.
<ALAC-Comments-gTLD Guide.odt><ALAC-Comments-gTLD Guide.doc>_______________________________________________ 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
*********************************************************** William J. Drake Senior Associate Centre for International Governance Graduate Institute of International and Development Studies Geneva, Switzerland william.drake@graduateinstitute.ch New book: Governing Global Electronic Networks, http://tinyurl.com/5mh9jj ***********************************************************
Bill and all, Yes, it may seem contradictory to suggest lot of changes and at the same time express concern about possible delays. Actually, I think the European concern is more directed towards some North American calls to drop the process entirely or suspend it until a series of long studies are performed on the relevance to the market of the whole new gTLD process. I suggest an amendment to the text that would read: "The EURALO does not support recent calls to delay the new gTLD process until additional studies are performed. 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 understand that ICANN needs to carefully examine and address concerns raised in the numerous comments that were submitted. However, we are convinced they can be dealt with without slowing down dramatically the ongoing process." To reply to Annette: I had a discussion with some NARALO members, and they disagree about the "no further delay" paragraph. Hence, I expect the common ALAC statement to be silent about that. The full Euralo statement is here: https://st.icann.org/euralo/index.cgi?euralo_additional_statement_regarding_... Best, Patrick On Tue, 27 Jan 2009 14:34:47 +0100, William Drake <william.drake@graduateinstitute.ch> wrote:
Hello,
Thanks to Patrick, Adam and others for pushing this forward. Appending regional comments to the ALAC statement seems like a good idea. I wonder though about the key sentence, "EURALO does not support recent calls for a delay to the new gTLD process." I'm not clear on how this conclusion fits with the laundry list of concerns raised in both the EURALO and ALAC texts. Together, they say we want ICANN to rethink registry/registrar separations; amend the guide's requirements regarding the use of registrars; have a different approval process for geographical, community bounded, non-commercial, not-for-profit gTLDs; change the one-size-fits all fee structure; improve compliance processes; build in public interest oriented mechanisms; get rid of MAPO objections; drop ICC arbitration; change the number of applications contemplated in the first round; and develop a comprehensive resourcing plan for the new gTLD program. How could addressing all these concerns not involve delays in the process? Can we really have it both ways? Would we be happy if the board cited the "no delays" headline conclusion as support for moving forward, but then didn't address fully the concerns raised? Is that a far-fetched scenario?
Hi Patrick, Thanks for clarifying the intention, the new first sentence seems apt (assuming this is in fact a strong majority view in Euralo, not many responses yet so I don't know). I wonder though if maybe it might also be good to tweak a bit more, perhaps like, "The EURALO does not support recent calls to delay the new gTLD process until additional studies are performed. 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. At the same time, we believe that ICANN needs to carefully examine and address the public interest concerns raised by ALAC and others. We very much hope that these can be fully addressed without slowing down dramatically the ongoing process." Reasons: *We believe that is stronger than we understand, which sounds like a concession to an unfortunate condition *Saying that ICANN needs respond to the concerns raised in the numerous comments submitted is pretty broad, and not all the comments are consistent with ALAC's concerns. For present purposes, wouldn't it be better to specify that we are asking that it's the public interest concerns of ALAC and others be addressed? (since I have one foot here and one in NCUC, which has written a pretty thorough critique of the process, I'd have rather said NCUC than "others," but someone here wouldn't prefer that...?) *Saying "we are convinced" it can be done seems a leap of faith, I'd rather express a hope. And "fully addressed" seems stronger than "dealt with." One could "deal with" concerns by briefly mentioning and dismissing them. Just copy editing suggestions, I'll roll with whichever version has strong support in the group. Best, Bill On Jan 30, 2009, at 9:39 AM, Patrick Vande Walle wrote:
Bill and all,
Yes, it may seem contradictory to suggest lot of changes and at the same time express concern about possible delays. Actually, I think the European concern is more directed towards some North American calls to drop the process entirely or suspend it until a series of long studies are performed on the relevance to the market of the whole new gTLD process.
I suggest an amendment to the text that would read:
"The EURALO does not support recent calls to delay the new gTLD process until additional studies are performed. 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 understand that ICANN needs to carefully examine and address concerns raised in the numerous comments that were submitted. However, we are convinced they can be dealt with without slowing down dramatically the ongoing process."
To reply to Annette: I had a discussion with some NARALO members, and they disagree about the "no further delay" paragraph. Hence, I expect the common ALAC statement to be silent about that.
The full Euralo statement is here: https://st.icann.org/euralo/index.cgi?euralo_additional_statement_regarding_...
Best,
Patrick
On Tue, 27 Jan 2009 14:34:47 +0100, William Drake <william.drake@graduateinstitute.ch> wrote:
Hello,
Thanks to Patrick, Adam and others for pushing this forward. Appending regional comments to the ALAC statement seems like a good idea. I wonder though about the key sentence, "EURALO does not support recent calls for a delay to the new gTLD process." I'm not clear on how this conclusion fits with the laundry list of concerns raised in both the EURALO and ALAC texts. Together, they say we want ICANN to rethink registry/registrar separations; amend the guide's requirements regarding the use of registrars; have a different approval process for geographical, community bounded, non-commercial, not-for-profit gTLDs; change the one-size-fits all fee structure; improve compliance processes; build in public interest oriented mechanisms; get rid of MAPO objections; drop ICC arbitration; change the number of applications contemplated in the first round; and develop a comprehensive resourcing plan for the new gTLD program. How could addressing all these concerns not involve delays in the process? Can we really have it both ways? Would we be happy if the board cited the "no delays" headline conclusion as support for moving forward, but then didn't address fully the concerns raised? Is that a far-fetched scenario?
*********************************************************** William J. Drake Senior Associate Centre for International Governance Graduate Institute of International and Development Studies Geneva, Switzerland william.drake@graduateinstitute.ch New book: Governing Global Electronic Networks, http://tinyurl.com/5mh9jj ***********************************************************
I am fine with your proposed changes. Obviously your English drafting is better than mine ;-) -Patrick On Fri, 30 Jan 2009 12:10:50 +0100, William Drake <william.drake@graduateinstitute.ch> wrote:
Hi Patrick,
Thanks for clarifying the intention, the new first sentence seems apt (assuming this is in fact a strong majority view in Euralo, not many responses yet so I don't know). I wonder though if maybe it might also be good to tweak a bit more, perhaps like,
"The EURALO does not support recent calls to delay the new gTLD process until additional studies are performed. 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. At the same time, we believe that ICANN needs to carefully examine and address the public interest concerns raised by ALAC and others. We very much hope that these can be fully addressed without slowing down dramatically the ongoing process."
Reasons:
*We believe that is stronger than we understand, which sounds like a concession to an unfortunate condition
*Saying that ICANN needs respond to the concerns raised in the numerous comments submitted is pretty broad, and not all the comments are consistent with ALAC's concerns. For present purposes, wouldn't it be better to specify that we are asking that it's the public interest concerns of ALAC and others be addressed? (since I have one foot here and one in NCUC, which has written a pretty thorough critique of the process, I'd have rather said NCUC than "others," but someone here wouldn't prefer that...?)
*Saying "we are convinced" it can be done seems a leap of faith, I'd rather express a hope. And "fully addressed" seems stronger than "dealt with." One could "deal with" concerns by briefly mentioning and dismissing them.
Just copy editing suggestions, I'll roll with whichever version has strong support in the group.
Best,
Bill
On Jan 30, 2009, at 9:39 AM, Patrick Vande Walle wrote:
Bill and all,
Yes, it may seem contradictory to suggest lot of changes and at the same time express concern about possible delays. Actually, I think the European concern is more directed towards some North American calls to drop the process entirely or suspend it until a series of long studies are performed on the relevance to the market of the whole new gTLD process.
I suggest an amendment to the text that would read:
"The EURALO does not support recent calls to delay the new gTLD process until additional studies are performed. 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 understand that ICANN needs to carefully examine and address concerns raised in the numerous comments that were submitted. However, we are convinced they can be dealt with without slowing down dramatically the ongoing process."
To reply to Annette: I had a discussion with some NARALO members, and they disagree about the "no further delay" paragraph. Hence, I expect the common ALAC statement to be silent about that.
The full Euralo statement is here:
https://st.icann.org/euralo/index.cgi?euralo_additional_statement_regarding_...
Best,
Patrick
On Tue, 27 Jan 2009 14:34:47 +0100, William Drake <william.drake@graduateinstitute.ch> wrote:
Hello,
Thanks to Patrick, Adam and others for pushing this forward. Appending regional comments to the ALAC statement seems like a good idea. I wonder though about the key sentence, "EURALO does not support recent calls for a delay to the new gTLD process." I'm not clear on how this conclusion fits with the laundry list of concerns raised in both the EURALO and ALAC texts. Together, they say we want ICANN to rethink registry/registrar separations; amend the guide's requirements regarding the use of registrars; have a different approval process for geographical, community bounded, non-commercial, not-for-profit gTLDs; change the one-size-fits all fee structure; improve compliance processes; build in public interest oriented mechanisms; get rid of MAPO objections; drop ICC arbitration; change the number of applications contemplated in the first round; and develop a comprehensive resourcing plan for the new gTLD program. How could addressing all these concerns not involve delays in the process? Can we really have it both ways? Would we be happy if the board cited the "no delays" headline conclusion as support for moving forward, but then didn't address fully the concerns raised? Is that a far-fetched scenario?
*********************************************************** William J. Drake Senior Associate Centre for International Governance Graduate Institute of International and Development Studies Geneva, Switzerland william.drake@graduateinstitute.ch New book: Governing Global Electronic Networks, http://tinyurl.com/5mh9jj ***********************************************************
Dear Patrick and Bill, I appreciate your way of consensus finding -- which is almost typically Swiss style ;-) I take this as an example of EURALO best practise and I am looking forward to more EURALO statements on ICANN issues like this. Thanks for your work and alle the best, Wolf Patrick Vande Walle wrote Fri, 30 Jan 2009 12:34:
I am fine with your proposed changes. Obviously your English drafting is better than mine ;-) -Patrick
On Fri, 30 Jan 2009 12:10:50 +0100, William Drake <william.drake@graduateinstitute.ch> wrote:
Hi Patrick,
Thanks for clarifying the intention, the new first sentence seems apt (assuming this is in fact a strong majority view in Euralo, not many responses yet so I don't know). I wonder though if maybe it might also be good to tweak a bit more, perhaps like,
"The EURALO does not support recent calls to delay the new gTLD process until additional studies are performed. 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. At the same time, we believe that ICANN needs to carefully examine and address the public interest concerns raised by ALAC and others. We very much hope that these can be fully addressed without slowing down dramatically the ongoing process."
Reasons:
*We believe that is stronger than we understand, which sounds like a concession to an unfortunate condition
*Saying that ICANN needs respond to the concerns raised in the numerous comments submitted is pretty broad, and not all the comments are consistent with ALAC's concerns. For present purposes, wouldn't it be better to specify that we are asking that it's the public interest concerns of ALAC and others be addressed? (since I have one foot here and one in NCUC, which has written a pretty thorough critique of the process, I'd have rather said NCUC than "others," but someone here wouldn't prefer that...?)
*Saying "we are convinced" it can be done seems a leap of faith, I'd rather express a hope. And "fully addressed" seems stronger than "dealt with." One could "deal with" concerns by briefly mentioning and dismissing them.
Just copy editing suggestions, I'll roll with whichever version has strong support in the group.
Best,
Bill
On Jan 30, 2009, at 9:39 AM, Patrick Vande Walle wrote:
Bill and all,
Yes, it may seem contradictory to suggest lot of changes and at the same time express concern about possible delays. Actually, I think the European concern is more directed towards some North American calls to drop the process entirely or suspend it until a series of long studies are performed on the relevance to the market of the whole new gTLD process.
I suggest an amendment to the text that would read:
"The EURALO does not support recent calls to delay the new gTLD process until additional studies are performed. 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 understand that ICANN needs to carefully examine and address concerns raised in the numerous comments that were submitted. However, we are convinced they can be dealt with without slowing down dramatically the ongoing process."
To reply to Annette: I had a discussion with some NARALO members, and they disagree about the "no further delay" paragraph. Hence, I expect the common ALAC statement to be silent about that.
The full Euralo statement is here:
https://st.icann.org/euralo/index.cgi?euralo_additional_statement_regarding_...
Best,
Patrick
On Tue, 27 Jan 2009 14:34:47 +0100, William Drake <william.drake@graduateinstitute.ch> wrote:
Hello,
Thanks to Patrick, Adam and others for pushing this forward. Appending regional comments to the ALAC statement seems like a good idea. I wonder though about the key sentence, "EURALO does not support recent calls for a delay to the new gTLD process." I'm not clear on how this conclusion fits with the laundry list of concerns raised in both the EURALO and ALAC texts. Together, they say we want ICANN to rethink registry/registrar separations; amend the guide's requirements regarding the use of registrars; have a different approval process for geographical, community bounded, non-commercial, not-for-profit gTLDs; change the one-size-fits all fee structure; improve compliance processes; build in public interest oriented mechanisms; get rid of MAPO objections; drop ICC arbitration; change the number of applications contemplated in the first round; and develop a comprehensive resourcing plan for the new gTLD program. How could addressing all these concerns not involve delays in the process? Can we really have it both ways? Would we be happy if the board cited the "no delays" headline conclusion as support for moving forward, but then didn't address fully the concerns raised? Is that a far-fetched scenario?
*********************************************************** William J. Drake Senior Associate Centre for International Governance Graduate Institute of International and Development Studies Geneva, Switzerland william.drake@graduateinstitute.ch New book: Governing Global Electronic Networks, http://tinyurl.com/5mh9jj ***********************************************************
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participants (3)
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Patrick Vande Walle -
William Drake -
Wolf Ludwig