At-Large Workspace: Work Track 1 - GNSO Community Comment 2 (CC2) on New gTLD Subsequent Procedures Policy Development Process

The At-Large Community is generally dubious of the value of ongoing expansion in gTLDs, given that the benefit from the previous round is yet to be proven. Documentation provided to the CCT-RT suggests that gTLD expansion actually exerts a negative effect on Internet users (that is, suppliers of Internet-based services and the end-users who partake of these services). As such, the internal relationships between contracted parties and their service providers is of relatively little import to Internet users.

While At-Large does not see any benefits from the further expansion of new gTLDs into the domain system, benefits could be achieved by the proposed programme to develop and enhance the technical and knowledge capacity of RSPs, especially for underdeveloped economies. In order to achieve the objectives of the GNSO recommendation there is a dire need for high level technical capacity building as well as ensuring that applicants have the appropriate  operational management knowledge, skills and understanding required to run a successful registry operation. Training and preparedness even for the pre-approval and the Pre-Delegation Testing must be a pre-requisite  level of entry for entrants as RSPs from underdeveloped economies considering such a venture.  

There would be value in ICANN providing such capacity development support covering all the appropriate criteria requirements for a RSP. Having an external regulatory body would would also ensure that RSPs in developing regions especially, met the minimum standards for redundancy, capacity, monitoring, reaction time to threats, reporting and statistical process controls.  In developing regions, monitoring and support to ensure that these standards are maintained by a regional regulatory body, perhaps under the auspices of ICANN, to regulate the performance of new RSPs and ensuring consistently high level of technical and governance processes.

The onus of compliance with the RAA is on the registry. At-Large is of no opinion on the benefits or drawbacks of separate regulation of service providers.

No. The onus of RAA compliance – and contact with ICANN – should remain with the Registry.

The origins of the AS program were always intended to include IDN support. This is not readily evident to be a problem that needs fixing. 

Considering that there were zero successful applicants from under-served or under-developed economies, attention should be focused to learning from that and making criteria less stringent for applicants from these areas. This involves potential expansion of the traditional definition of community applications, as well as the enabling of for-profit entities in under-served and underdeveloped economies to participate in the program.

This could include major technical training (for example, to increase the number of registrars in these regions) as well as knowledge and capacity building and access to appropriate resource personnel who could assist under-served and underdeveloped economies to better understand appropriate business models that would help them to successfully implement new gtlds based on lessons learned from previous new gtld experiences. Proactive consultation with key personnel from these economies to ascertain what their needs are in order to create a more successful development of new gtlds for this targeted group would be helpful.

Expanding a too-restrictive program to operate in richer economies will not, we believe, result in benefits consistent with the original aims of the program.

Rather than expanded to other regions, the AS program must be modified so it can be more-readily exploited in the regions it was originally intended to serve. Expansion to richer economies should not proceed until the AS is evidenced to be functional in the originally targeted regions. 

The primary focus of any changes to the Applicant Support program should be in the eligibility criteria or in supporting potential applicants to be able to meet appropriate eligibility standards as in 1.2.1. But also, there is a strong need for mentorship and continued support to be built into the support programme so that potential builders of new gtld operations are not just left to their own meagre resources after training to fend for themselves, as is usually the case with a lot of development programmes. Addressing the benefits in other areas is premature unless the rate of successful applications to rejections is dramatically improved.

The Applicant Support program was barely mentioned in the original ICANN promotion of the 2012 gTLD round, so any new communications will be an improvement and is critical to any successful outcomes for potential applicants in under-served or under-developed economies.

Referring to 1.2.1, and expanding training and awareness opportunities to be more inclusive of their needs in this area, primarily in facilitating and enabling these opportunities which requires funding and other resources to make them effective enablers for new gtld development in their regions. Inclusion of the Applicant Support program in all promotional activities related to new TLD applications would be sensible.

ICANN must be sensitive of the dire lack of resources related to Internet connectivity in least-developed economies. Where basic infrastructure and reliable access continues to be a challenge, ICANN must accept that existing availability of TLDs (ccTLDs and existing gTLDs) may be sufficient in regions where resources may be more effectively applied to critical local Internet infrastructure. ICANN would display poor global citizenship - and weaken public trust - if it promotes the investment of rare resources to new gTLDs in preference to core infrastructure.

Although the CCWG on Auction Proceeds is only just starting its discussions on how these funds might be used in the future, some consideration could be given to assisting LDCs to address and improve core needs with regards to gtlds and how they can help their countries and regions. One objective could be the development of outreach by registries and registrars into the underserved and underdeveloped sectors - implementing appropriate training programmes for developing locally situated registries/registrars that will address and support the needs of potential business, educational and social entrepreneurial LDC end-users. Meeting relevant on-going training needs, would also create a sustainable pool of trained personnel from within the region to manage and operate the use of new gtds as well as help to consolidate work with their own cctlds within their region. This would therefore help to build more capacity and confidence among a wider field of potential applicants. At the same time, training and infrastructure is not sustainable if mentoring and support from knowledgeable technical and management personnel is not continued as followup for local developers, to help them to successfully use their domains to expand their economic and social outreach into global networks, until such time as they are able to fly on their own.

In relation to the proposal in 1.2.1, metrics could be associated with the number of people within LDCs who opt for and are successfully trained as registrars, who

See response to 1.2.2. Improvement which starts at changing and supporting opportunities for people in under-served and underdeveloped economies to improve their chances to meet the eligibility criteria, will enable more potential applicants, in relevant regions, to succeed.

Specifically, the rule that prevented a failed 2012 Applicant Support effort from re-submitting as a conventional gTLD (without support) must be eliminated. This rule was believed to be a significant barrier to entry for many would-be applicants.

See response to 1.1.1

Such operational issues are of little concern to the general public.

See response to 1.1.1

Such operational issues are of little concern to the general public.

Hindsight is always 20-20.

ICANN made its calculations based on what it believed would be break-even, with absolutely no precedent.

Obviously a new calculation needs to be derived that may be able to, for instance, eliminate the historical-cost component if that has been fully recovered by the last round.

ICANN’s responsibility is to price the program based on cost recovery. Any other philosophical approach indicates needless bias towards either established players or would-be entrants - any such stance would be seen as political and a potential source of public mistrust.

“One fee fits all” is a reasonable standard, else applicants will work to game the system to achieve best advantage. There may be cause to reduce the fees for eligible community applications, and the Applicant Support program addresses those potentially unable to pay for identifiable reasons.

See response to 1.5.1. We do not believe that there should be differential pricing, except perhaps for community applications for which evaluation criteria already exists (and maybe worthy of revisiting)

No. The fee should not be changed based on the volume. There should be a level playing field for all. There should especially be no consideration for applicants for whom projections are not matched by market realities.

See response to 1.1.1

Regardless if done in rounds or in “first come first served” continual application processes, At-Large is skeptical of the public benefit of ongoing gTLD proliferation. More information, such as the data being collected by the CCT-RT, needs to be collected in order to make an informed judgment regarding the benefit or harm caused to Internet user by further gTLD expansion.

See response to 1.6.1. The choice of hard rounds or a continuous application process is less relevant to Internet users than the general concerns regarding potential harm to Internet users caused by gTLD proliferation.

See response to 1.2.1 The choice of hard rounds of continuous applications should not affect the Applicant Support program provided that the program (and specifically its evaluation criteria) is appropriately updated.

Applicants asking for Applicant Support and community evaluation be given priority.

ICANN’s Global Stakeholder Engagement team is responsible for promoting global awareness. At-Large does not have much authority to undertake any real communication activity without funding and other support from GSE and At-Large Support staff. However, communication to the masses is an important feature of getting the right messages out about ICANN, the DNS, etc, and the RSP and Applicant Support programmes, and the GSE team is not being totally successful in getting these out to under-served countries. However RALOs are disadvantaged when outreach opportunities funded by ICANN are limited to 5 CROP slots. This is a joke when you have RALOs like APRALO which deals with over 70 individual countries and with the fastest growth of end-users of all the regions. Such is the extent of this problem, regional teams need to be organised within underserved regions to more effectively Introduce, educate and inform people who may be qualified but without the right contacts to leanr about the RSP and Applicant Support programmes.