[EURO-Discuss] Proposed Euralo statement on the g TLD Applicant's guide

[Wolf Ludwig]

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 at vande-walle.eu>
>> Gesendet: 25.01.09 17:48:26
>> An: Discussion for At-Large Europe <euro-discuss at 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 – 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.
>> 
>> 
>> 
>> 
>> <hr>
>> _______________________________________________
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>> EURO-Discuss at atlarge-lists.icann.org
>> http://atlarge-lists.icann.org/mailman/listinfo/euro-discuss_atlarge-lists.icann.org
>> 
>> Homepage for the region: http://www.euralo.org
>> 
>
>-- 
>
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