AL.ALAC/ST.0609/5
ORIGINAL: English
DATE: 17th July 2009
STATUS: FINAL
Introductory Text
By the Staff of ICANN
The statement below is a response to an open public consultation. The information on that consultation may be found here: http://www.icann.org/en/announcements/announcement-31may09-en.htm
It was originally drafted by the ALAC Liaison for IDN Issues, Sivasubramanian Muthusamy, and was then published for review by the wider community on June 30th, 2009. The original version of the statement may be viewed here. Members of the At-Large community proposed some amendments to the original text, which the author incorporated into the final draft (a comparison between the original statement and the final version may be viewed here). The Chair of ALAC requested the Staff to begin a vote on the draft for a five day period, which began on 18th July 2009.
(End of Introduction)
ALAC comment on the 3rd Revision of the Draft Implementation Plan for IDN ccTLDs.
ALAC raises the following comments with a view to contribute to the process of evolving the Plan further as a complete Plan so as to ensure that IDN TLDs are smoothly implemented globally without technical or policy related implementation issues and seamlessly integrated in the domain name system. At the same time ALAC empathizes that all that needs to be examined needs to be examined expeditiously as expressed in the opinion within that 'Fast-track IDN ccTLDs must be implemented as planned, i.e. in Q4 of 2009 as the latest, to meet the "pressing need" of non-ASCII user community' [ With the view to expeditiously complete the IDN related tasks, it is proposed that ICANN incorporates in its agenda for the Seoul meeting a full day of meetings to focus on IDNs, scheduled as inter-constituency meetings attended by invited experts, staff and finance committees to reslove all pending issues related to IDN Policy and pave way for implementation ] ( The line in square brackets not to be part of the comemment statement and to be discussed and raised separately)
ALAC is in agreement in principle that “the request for an IDN ccTLD cannot proceed through the Fast Track Process if the Panel or review team identifies that a requested string raises significant security and stability issues” ( 4.1). ALAC awaits further details on on the plans for the the DNS Stability panel (Foot Note 1)
ALAC is committed to multi-stakeholder approach and notes positively the inclusion of the passage “The application should demonstrate there has been community dialogue regarding which string is the appropriate representation of the country in the selected string(s) and/or language(s)/script(s), and that appropriate stakeholders have been involved in the decision making process.” and feels that this passage alone could address the concerns of Governments and all stakeholders. (Foot Note:2) ALAC submits that the Draft Implementation Plan could particularly emphasize "a more broader role for local internet community in the respective countries in the IDN ccTLD Process"
ALAC feels that the topic of “Financial Contribution” or cost recovery, for instance could not be considered as a topic that can be “considered solved”. ALAC feels that more discussions are needed on the details of the proposed cost recovery model. (foot note 3)
ICANN estimates processing of IDN ccTLDs will cost approximately $24,391 per request plus $115,000 of fixed costs. The cost estimated for the processing of each new IDN ccTLD request is prohibitively high. The financial barrier for IDN ccTLD managers especially from developing countries would widen the digital divide and be against the ICANN's social responsibility. ALAC proposes that ICANN, instead, may consider a combined model of cost recovery - an affordable upfront fee together with a model by which the Registries could share a nominal fixed amount per domain from the price charged to the Registrant or a proportion of it which could be transferred to ICANN through the Registrar, through the Registries on an ongoing basis (foot note: 4)
Any implementation plan must strictly observe the IDN Guidelines and IDN tables reserved at the ICANN. Any ignorance on variant character set would cause serious user confusion. The present draft policy on variants would seriously pledge the non-ASCII users, particularly in Chinese, Japanese and Korean community, by distorting their character usage. If the present policy equals ASCII TLD variants in either capital letters or low-case letters, non-ASCII users should have the equal right to use the variant scripts in the relevant fast-track IDN ccTLDs.
(foot notes to be annexed to the comment statement)
Foot Note 1: In line with the IDNC WG Final Report, the external and independent DNS Stability Panel should be appointed to conduct technical due diligence and report to the ICANN Board. And in agreement with the IDNC WG report, the 3rd revision excludes the reference to the Registry Services Evaluation Process and the hint of DNSSEC but instead adds that “ICANN will secure the services of a competent technical panel (DNS Stability Panel) to make stability evaluations” And the report adds that “ICANN is finalizing the coordination of the DNS Stability panel and further details will be made available”. ALAC awaits further details
Foot Note 2: The 3rd revision further enhances the role of Governments in the IDN ccTLD application process with its emphasis on “evidence of support” and the deletion of evidence of “non-objection” as documentation requirements in the Preparation Stage. As in previous drafts, the 3 rd revision retains its position that such evidence of support needs to be from “the Minister with the portfolio responsible for domain name administration, ICT, foreign affairs or Office of the Prime Minister or President; or a senior representative of the agency or department responsible for domain name administration, ICT, Foreign Affairs or the Office of the Prime Minister.” While this stipulation reflects the positive involvement of Governments in the IDN TLD process and their concerns, and is in tune with ICANN's ccTLD delegation policies, ALAC notes with apprehension that International Domain Names as ccTLDs, together with ascii ccTLDs could enable governments to control access and curtail civil liberties. ALAC expresses concern about the emphatic reference to Governments which in effect makes the Governments as the requesters, either directly or indirectly (emphasis for attention in the comment draft - redraft process). The description of the Preparation Stage process ( 5.1.1) specifies 1) 1. Support from the relevant government or public authority 2) Support ... by the relevant government, ALAC expresses concerns on this continued and emphatic references to Governments as total deviation from the gTLD processes and principles.
Foot Note 3: ALAC notes that the 3rd revision excludes portions of Module 7 of the 2nd revision purportedly "to only contain discussions of outstanding issues". Topics deleted from the previous versions of the plan are “considered solved” though included elsewhere in the plan “as deemed necessary”. Module 7: Discussion of Additional Topics has been entirely deleted in the third revision with the observation that “most of the topics remaining in this module relate directly to the overarching requirements to Preserve the security and stability of the DNSand Ensure compliance with the IDNA protocol and IDN Guidelines. The remaining topics included have all been addressed in supporting papers to this plan, for which the hypertext links were not embedded, for instant reference. Alac wishes to comment that the topics could have been listed under a separate section of the report as topics considered solved to retain the extent and depth of topics related to the IDN TLD process.(ALAC notes that considerable time and efforts have spent by the ICANN staff to further the IDN policy process. The points raised in reference to the absence of links to documents etc. are general, minor observations, and to be taken as a suggestion for maintaining the completeness of the draft implementation report. It is NOT implied that this is a serious omission.This comment relates to the structure of the draft implementation plan and may only be taken as a suggestion for better convenience for readers in further documentation)
Foot Note 4: ICANN estimates processing of IDN ccTLDs will cost approximately $24,391 per request plus $115,000 of fixed costs. As expressed by a participant's comment during a Sydney session, these costs have not taken into account the external costs of time spent on IDN discussion by constituencies and external volunteers and various governmental and non-governmental groups working on IDN development. Such external costs may not be costs incurred by ICANN and most of which may not be due for recovery by ICANN, but such costs need to be considered to arrive at the overall global costs in IDN development, to arrive at a notional 'value' of IDN development. Of the overall costs or 'value' of development, if what is to be recovered are to be recovered by a cost-recovery model UPFRONT (though there is no conclusive pointers to a decision at ICANN for cost-recovery on this model), it could be a deterrent for several requesters. There was an indication of a percentage contribution of (a registry's revenue) for cost recovery, and in this regard, ALAC wishes to point out that the Registry level revenue would be a fraction of the overall Retail revenue, and in some cases the Registries may transfer IDN TLDs to registrars at low or zero prices. So, there is a possibility of a shortfall in cost recovery. As it is foreseen that the end user would part with an average of $3-10 per IDN, ALAC wishes to suggest a model by which a percentage of the Street Retail Value charged to the Registrant, or the first ten or twenty five cents billed to the Registrant could be earmarked as contribution to ICANN and could be transferred to ICANN by the Domain Retailer through the Registrar and Registry, as an easier model of cost recovery, perhaps in combination of an affordable upfront fee for IDN requests.
[ Foot Note 4 Summary. ICANN has so far spent US $ 6 million on the IDN program. There would be application processing costs in addition. So it would charge an initial fee from the applicant (Requestor). The initial fee is to cover application processing costs. ALAC feels that the initial fee should be low.
(To recover the costs of development) ICANN plans to ask ccTLDs to share 3% of their revenues. Some Registries fix a nominal price per domain, so 3% of the Registry 's revenues would not be much. ALAC proposes that the Registries can share a percentage of the FINAL price of an IDN domain. Or ask the registries to collect 10 cents or 25 cents per IDN from the Domain Reseller and transfer to ICANN. Usually end user is charged $3 - $10 per domain, of which 10 cents or 25 cents can go to ICANN for cost recovery. This would make it easier for the Registry because the initial costs are low. This is also a better model for ICANN as it would bring in better revenue for its programs. ]
