Final Statement in PDF - 10 Dec 2009

ALAC Statement on Draft Topic Paper for Policy on the Introduction of IDN ccTLD

Note: The wordings in italics are meant for ALAC discussion and will not be part of the final statement.

ALAC is please to see ccNSO undertaking the enormous and challenging task of developing the policy for IDN ccTLD.

ALAC has reviewed the Draft Topic Paper for Policy on the Introduction of IDN ccTLDs.

We would like to propose the following questions for ccNSO IDN PDP WG1 considerations.

1) How does one select IDN ccTLD operator for a territory? Can a third party be an IDN ccTLD operator? If so, what is the criteria and process for the selection of IDN ccTLD operator? If there is more than one IDN ccTLD strings for a territory, can it go to different operators?

Rationale: There are user voices within certain territories who believe they are not been well serve by existing ccTLD operators, or that the government mandated operator may not be in the best interest of the community. The selection of the IDN ccTLD operator should take into public, private and community recommendations into consideration.

2) Additional to Topic 2: Should the IDN ccTLD string be related to the territory name?

Rationale: ccTLD should be use related to country code. For example, and no offense intended by the example, .tv should not have IDN .Television via IDN ccTLD PDP process. dotTV could of course apply IDN .Television via IDN gTLD process.

3) Additional to Topic 3: Should there be a limited on the numbers of IDN ccTLD string per territory? Or should there be limited on how many IDN ccTLD string a territory can apply per year?

Rationale: In consideration of the Root Scaling Report, we should carefully control how many new TLD we introduce the root zone file to ensure DNS stability.

4) Additional to Topic 3: Should IDN ccTLD string be delegated per language or per script?

Rationale: There are territory where the writing system for their language uses more than one script. Shouldn't they be allowed to have in all script?

5) Additional to Topic 5: Should there be a technical requirement to implement IPv6 and DNSSEC?

Rationale: Both IPv6 and DNSSEC are critical technology that is essential for long term stability of the Domain Name System and the Internet.

6) Additional to Topic 8: Who select or delegate the group that has the “rights” to a particular script of the IDN ccTLD?

Rationale: A group that has rights to a particularly script may imply certain group may have influence whether a IDN ccTLD of the script be delegated. For example, XXX group have a special right to "Chinese script" and they have influence over whether Chinese IDN of .UK or .US be delegated. We should have procedure to select this group, if we decided to have, carefully.

7) Additional to Topic 12: If a territory is granted multiple IDN ccTLD strings in different scripts but in the same language, e.g. variants of the same IDN ccTLD, should it be allowed to charge registrants multiple times for each IDN ccTLD strings in different scripts?

Rationale: For example, if China is granted .CHINA in traditional and simplified Chinese, should registrants of the ccTLD has to pay 2x for the same name under two different TLD?

ALAC would like to thank ccNSO for giving the public the opportunity to provide feedback to its considerations.

James Seng
ALAC, IDN Liaison

I cannot join the call. Please see my comments below:
1) This is an important issue. There are two options: a)following fast-track model; and b)applying re-delegation policy and procedure. No matter which way to go, delegation of the IDNccTLD operator should be subject to the multi-stakeholder process within the given ccTLD territory.
2)Fast-track has set up precedent and should be followed in the PDP.
Hong Xue, CDNUA

contributed by on 2009-12-03 10:18:58 GMT

Having looked at the clean version of this proposed statement I support the points raised in it and think it is ready for transmission to the ccNSO-IDN-WG as soon as ratified (or before noting it is under ratification... As James now serves on that WG I believe he should do this ASAP, as the ALAC goes into the Confirm Final Draft and Vote stages of our Statement Development process... CLO

contributed by on 2009-12-03 22:40:21 GMT

my comments :

  • 1) and 2) are covered in the delegation process and also on ccTLD IDN fast track, new IDN ccTLD PDP should not change those outcomes .
  • point 7 is not relevant as ccTLD registration policies are developed on a national level, no external power can influence that, its a registry level decision regarding how to deal with string variants or registrations of multiple domains
  • 4) its will better for end user if IDN ccTLD are language based, e.g There are many languages are using Arabic Script, and there is different Arabic Script language tables so a unified script table is hard to mandate, those communities has the right to apply for IDN ccTLD in their languages using their own script tables.
  • 6) if selecting sting is an official language, and the internet community in that country agreed to use this string, it can be applied for, this is an country decision to make .

i could invisage a case that can be related to this point .

Thank you James for the draft .


contributed by on 2009-12-04 12:02:38 GMT

I believe Mohamed's comments touch the key issue of this PDP. What is the relation between the PDP and the fast-track policy? If the PDP is going to set up policy different from the fast-track, should it be applied to fast-track implementation retrospectively? If so, it will no doubt be disastrous. Delegation of IDN ccTLD operators is particularly a sensative issue and should be handled with sufficient delicacy. Policy consistency, IMHO, should be prioritized for stablity and security of DNS.

Commented by Hong Xue, CDNUA

ccNSO WG1 on IDN ccTLD PDP hasn't formulate their position either (or maybe they have but it is not public). The Draft Topic Paper for public consultation only reveal the Questions they would like to ask themselves and the community but not their position.

At this stage, we need to come up with Questions, not Answers. There will be time for debate/discussion on the answers to these questions.

However, the discussion above is useful for me to know of ALAC position. I encourage we continue this discussion on the wiki or the mailing list.

Thank you and please keep the discussion going.

In respond to Xue Hong, at this moment there is no indication whether there will be differences in policy between Fast-Track and PDP since the latter is not defined yet. However, to ask for 100% consistency between Fast-Track and PDP may not be possible since one cannot ensure that until PDP is finalized, which, of cos, would defect the purpose of Fast Track. What we can request is that PDP should follow the principle of the Fast-Track as much as possible, and if it differs, there should be a very good reason for the differences.

Commented by James Seng

contributed by on 2009-12-05 02:38:12 GMT

contributed by on 2010-03-31 01:12:01 GMT