Re: [ga] Nominet UK's response to ICANN's Strategic Plan

[Jeff Williams <jwkckid1@xxxxxxxxxxxxx>]

Richard and all former DNSO GA members or other interested
stakeholders/users,

  It is interesting but not surprising to read that Nominet being the
registry
for .uk, as anti-international cooperation organization.

  It may be time to consider reallocating or reassigning .uk to a
different
organization as it's registry...  I am sure the united kingdom's PM and
Parliament will be getting request to consider such...

Richard Henderson wrote:

>    I have included, below, the response of Nominet (the UK's ccTLD
> registry) to ICANN's Strategic Plan. There is a clear wish and
> invitation for ICANN to become more involved and integrated with the
> local internet communities around the world, and to consider
> co-operative approaches rather than independent outreach initiatives
> in various countries. Section 8 is interesting because it flags up
> just how little actual participation there is, to date, in ICANN's
> ccNSO : just 17% of all ccTLDs, and most of those very small ones. In
> this context, any decision-making process which explores money-raising
> from ccTLDs ( and this could amount to a third of ICANN's
> money-raising requirements) needs to more proactively involve the
> other 83% of ccTLDs. Registries like Nominet do not see why they
> should levy a charge, say, on domain registrations to finance gTLD
> areas, or fund areas which are already provided at a country level by
> ccTLD registries. In short, ICANN needs to justify any money it seeks
> to appropriate from ccTLDs and if this is to be achieved consensually
> then it needs to get more ccTLDs truly on board. Why should British
> registrants, registering domain names in their own country, be asked
> to pay for the processes needed to expand gTLDs or US-based
> registries? Any commercial expansion of gTLDs should occur in a
> commercial environment, based on investment and returns, and supported
> by gTLDs themselves, not propped up by "taxes" on ccTLDs.
>
> The Nominet letter is copied out below:
>
> Yrs, Richard Henderson www.atlarge.org
>
>
>
> Dear Paul
>
> ICANN Strategic Plan
>
> Nominet UK, the country code Top Level Domain registry for .uk, thanks
> ICANN for the opportunity to comment on the ICANN Strategic Plan
> 2003-04 to 2006-7. We fully recognise that it will have been a major
> piece of work and no easy task to produce the Plan and to develop the
> strategic priorities contained within it. In our experience, it can be
> challenging to develop strategic plans that balance the sometimes
> conflicting needs of a large range of stakeholders, during a period of
> rapid external and internal change. The publication of the Plan will
> assist in establishing dialogue between stakeholders and ICANN and
> will also assist in establishing priorities. Our feedback on the Plan
> should therefore be set in this context and is intended to be
> constructively supportive. We have resisted the temptation to make
> overly detailed comment, but would be happy to amplify on any area
> should this be considered helpful.
>
> 1. General Strategic Plan Content Much of the content of the Plan
> details ICANN's achievements to date and 'Where we are now'. This will
> be informative for stakeholders new to ICANN and is helpful in setting
> the background to the strategic plan. However, the areas detailing
> 'Where we are going' and 'How and when we are going to get there' are
> comparatively less developed and detailed. Given the nature and extent
> of some of the proposed developments, it would perhaps be helpful to
> develop these aspects of the Plan further. In particular, we would
> suggest the full allocation of projects or initiatives to particular
> years of the Plan period and the identification of priorities and
> progress milestones. The further development of these aspects would
> then assist ICANN staff with the setting and management of stakeholder
> expectations, the development of a project programme, the development
> of the financial strategy and the budget process.
>
> 2. Strategic Priorities The mission of ICANN stresses its role in
> ensuring the stable and secure operation of the Internet's unique
> identifier systems and strategic priority one is identified in the
> Plan as stability and security. It is not clear whether the priorities
> are in order of importance. Nominet believes that this is the most
> crucial of ICANN's strategic priorities and should be identified as
> such. The stability and security section of the Plan also appears to
> be relatively light in contrast to the other strategic priorities. We
> assume that this is because the focus is on strengthening what is
> already in place, but would suggest that assessment of the size of the
> 'gap' between the current and desired positions for each of the
> priorities would help stakeholders better understand the strategic
> plans. With regard to strategic priority two, it needs to be made
> clearer that the development and management of initiatives that foster
> competition and consumer choice, whilst supporting compliance with
> existing policies and contracts, applies only to the gTLD market. For
> the ccTLDs, competition and consumer choice at registrar level is a
> responsibility of the respective governments, registries and local
> Internet communities.
>
> 3. Financial Strategy The need to develop and implement a financial
> strategy is identified within the plan, but it is not clear when or
> how this will be developed and what changes to the Plan may need to be
> contemplated if ICANN's income exceeds projections, does not meet
> projections or if costs, such as those related to litigation, increase
> significantly. Given that the ICANN funding requirement is projected
> to increase by 165% during the life of the Plan and that
> diversification of income sources may well take some time to develop,
> it would be helpful to develop the financial strategy at an early
> stage. We would recommend from experience that this should include the
> development of multiple scenarios, varying some of the key assumptions
> that will affect finances, such as the stated assumption that overall
> domain growth will continue at 15% per annum. It should also be
> acknowledged by all ICANN stakeholders that the Plan may need to be
> iterated several times, depending on income levels. It might also be
> possible to develop partnerships with other members of the Internet
> community to reduce costs, for example, to assist with the provision
> of accommodation to establish an ICANN presence in each ICANN region.
> In turn, this may also provide the benefits of building closer
> relationships and mutual understanding with members of the Internet
> community.
>
> 4. Communications Strategy The need to develop and implement a
> communications strategy is identified within the plan, but it is not
> clear when or how this will be developed. It is suggested that this
> should be developed as early as possible during the Plan period,
> particularly as the cost of the comprehensive and multilingual
> strategy that is being proposed may perhaps have been difficult to
> estimate at this stage. It may also be possible to develop
> partnerships with other members of the Internet community to reduce
> communication costs, for example by using existing regional and local
> mechanisms and fora. In turn, this may also provide the benefits of
> building closer relationships and mutual understanding with members of
> the Internet community.
>
> 5. Human Resources Strategy The need to develop and implement a Human
> Resources strategy does not appear to have been identified within the
> plan, and it is not clear whether such a strategy already exists.
> Given that the number of ICANN staff is forecasted to increase by 50
> (167%) over current numbers during the Plan period and that some staff
> will be based internationally, it is suggested that if there is not an
> existing strategy, this should be developed at an early stage in order
> to attract, train and retain talented and able staff. Nominet speaks
> with some experience of this issue, having experienced similar
> percentage changes in staffing in response to market demand. It should
> also be recognised that the recruitment and training of this number of
> staff within the suggested time period will be challenging and may
> have a considerable impact on the ability of the management team to
> implement the many new projects that will be likely to result from the
> agreement of the Plan. Indeed, in our own experience, management and
> staff capacity rather than capability can often become an issue.
>
> 6. Uniform Dispute Resolution Policy (UDRP) We note that there appears
> not to be any reference to the updating of the UDRP in the Plan, which
> may well be disappointing to the Intellectual Property community and
> to registrants covered by the UDRP. As you may be aware, Nominet runs
> a Dispute Resolution Service for .uk domain name disputes, which has
> recently been revised for the second time since its inception, in
> response to Local Internet Community feedback.
>
> 7. IANA Nominet welcomes the proposals to strengthen the core IANA
> services and to improve support services for those that use IANA. The
> IANA function is of crucial importance to Nominet, other ccTLDs and
> the gTLDs and so it is hoped that these proposals will be implemented
> during the early years of the plan. Nominet would be happy to offer
> our experience and assistance in developing the more detailed vision
> and implementation plans that will need to follow in order to realise
> these proposals.
>
> 8. ccTLD Participation in ICANN We note that the Plan reports that
> ccTLD managers participate through the ccNSO in ICANN's policy
> development process. However, the ccNSO is still at an early stage.
> Given that only 17% of ccTLDs have joined the ccNSO to date and this
> number includes a disproportionate number of small ccTLDs, this
> statement should perhaps be more properly expressed as an aspiration.
> We acknowledge and appreciate the fact that ICANN is currently seeking
> to address this issue and has been responsive to our suggestion that
> ccNSO reform offers a way forward, but this may take some time.
> Therefore, whilst the ccNSO is in a formative stage, the Plan should
> identify as a priority mechanisms for the continuation of constructive
> dialogue and liaison with the members of the ccTLD community who have
> not joined the ccNSO during the period of the plan, such as via the
> CENTR organisation.
>
> 9. ccTLD Funding of ICANN We note the Plan expectation that the ccTLD
> community will collaborate through the ccNSO to devise a methodology
> for its ICANN contributions. However, given the low membership of the
> ccNSO at this formative stage, the Plan may also need to include other
> mechanisms for dialogue with the 83% of ccTLDs who are currently not
> members of the ccNSO, particularly as a 33% contribution increase is
> projected in the first year of the Plan. It is assumed that the
> recommendation of the 1999 Task Force on Funding, which suggested that
> ccTLDs contribute a 35% share of ICANN's continuing revenue
> requirements, will be reviewed as part of the development of the
> funding methodology. As you will be aware, Nominet and many other
> ccTLDs feel that they should not be required to resource activities
> that do not concern them such as fostering gTLD competition, registrar
> compliance and gTLD registrant support. Neither do we feel that we
> should be required to fund activities that are already funded by us at
> a Local Internet Community level such as dispute resolution, local
> policy development and registrant support. We note that revised
> Governmental Advisory Committee principles have been published since
> the Plan was first drafted, which will need to be taken into account
> when iterating the Plan. We agree with the stated GAC main principle
> of subsidiarity and that ccTLD policy should be set locally, unless it
> can be shown that the issue has global impact and needs to be resolved
> in an international framework. Like many ccTLDs, Nominet already funds
> a policy development process that seeks to involve all relevant local
> stakeholders. Nominet and the UK Local Internet Community therefore
> remain strongly against any form of domain name transaction or
> billable event based fee. However, Nominet stands ready to fund our
> fair share of IANA and ICANN services that are directly relevant to
> ccTLDs. I do hope that this feedback will be of use to you as you
> further develop and implement the Plan. Nominet endorses the
> coordination, collaboration and cooperation approach that is now being
> taken by ICANN and thanks ICANN for the opportunity to comment on its
> Strategic Plan.
>
> Yours sincerely
>
> Lesley Cowley (Mrs.)
>
> Chief Executive Nominet UK
>
>

Regards,

--
Jeffrey A. Williams
Spokesman for INEGroup LLA. - (Over 134k members/stakeholders strong!)
"Be precise in the use of words and expect precision from others" -
    Pierre Abelard

"If the probability be called P; the injury, L; and the burden, B;
liability depends upon whether B is less than L multiplied by
P: i.e., whether B is less than PL."
United States v. Carroll Towing  (159 F.2d 169 [2d Cir. 1947]
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