(Fwd) Fwd: IAB comments on Green Paper
For information, in case you haven't seen it already. Niall O'Reilly ------- Forwarded Message Follows ------- Date: Tue, 24 Feb 1998 09:43:44 +0000 From: John Martin <martin at terena.nl> (by way of Michael Walsh) Subject: Fwd: IAB comments on Green Paper To: niall.oreilly at ucd.ie For info, Michael.
Date: Mon, 23 Feb 1998 11:41:39 +0000 From: Brian E Carpenter <brian at hursley.ibm.com> Organization: IBM Internet Division Mime-Version: 1.0 To: ietf at ns.ietf.org Subject: Fwd: IAB comments on Green Paper
Note to the IETF from the IAB:
The IAB has carefully studied the US Government Green Paper at http://www.ntia.doc.gov/ntiahome/domainname/dnsdrft.htm and has considered the opinions expressed on the IETF and other mailing lists. We have sent the attached note to Ira Magaziner in response to the Green Paper.
The IAB will not comment on who should or should not be entitled to operate a gTLD registry. There is clearly no consensus on this in the IETF. It is also a question affecting business practices, which is not a legitimate subject of debate for a standards organization under anti-trust law. The IAB was happy to nominate technical representatives to the IAHC, and to the gTLD-MOU POC, and within reason would do the same for any IANA-approved gTLD registry requesting technical advice.
Subject: IAB comments on Green Paper Date: Mon, 23 Feb 1998 11:33:41 +0000 From: Brian E Carpenter <brian at hursley.ibm.com> To: Ira Magaziner <Ira_C._Magaziner at oa.eop.gov> CC: iab at iab.org
To: Ira C Magaziner From: Internet Architecture Board
Ira,
1. The IAB generally welcomes the proposal to replace US Government funding of the central technical administration of the Internet by a new non-governmental body with widely based, international participation. The IAB, as a technical group, will not take a position on details of the public policy aspects of the proposal.
2. There appears to be considerable confusion in the community about the definition of 'registry' as presented in this paper. It is our understanding that this is meant to identify a shared database for registrations in a TLD. There are no technical limitations to management of such a database by multiple parties, even if the database is physically unique for technical reasons. The discussion concerning 'lock-in' reinforces the viewpoint that a single entity would control a database and therefore a gTLD. We do not believe this is required by database technology. As this issue is one of the most contentious, clarification of the text is required.
Assuming we have correctly interpreted the word 'registry', the IAB wishes to point out that there is no technical reason for the proposed limit of one gTLD per such registry.
On the other hand, a very large increase in the total number of gTLDs (say to thousands) would lead us into technically unknown territory.
We note that the green paper attempts to define specifics and details concerning the number of gTLDs, the number of registries, and the number of gTLDs per registry. In keeping with the principles that have allowed the Internet to flourish, that is, bottom-up consensus-building and self-determination, we encourage the US government to avoid specific detail and, instead, allow self governance the opportunity to determine the details. We also note that considerable progress has been made over the last 12 months in developing gTLD criteria and dispute resolution procedures, and this progress is not adequately recognized in the green paper.
3. The IAB is a committee of the IETF, the open international voluntary standards organization for basic Internet protocols. We are therefore concerned that the proposed responsibility of the new corporation to
coordinate the development of other technical protocol parameters as needed to maintain universal connectivity on the Internet.
might be misread in such a way as to undermine the autonomy of the IETF. We propose that the word "development" should be replaced by the word "assignment". This would be consistent with the existing relationship between the IANA and the IETF, which has proved beneficial to all parties.
4. We support the authority of the current IANA, including that over the DNS root, throughout the transition period and we will be very happy to assist in any measures to reinforce that authority.
Kind regards,
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Brian E Carpenter (IAB Chair) brian at hursley.ibm.com IBM United Kingdom Laboratories http://www.hursley.ibm.com/~bc/ MP 185 phone: +44 1962 816833 Hursley Park fax: +44 1962 818101 Winchester Hampshire SO21 2JN, UK
John Martin TERENA, Singel 466-468, NL - 1017 AW Amsterdam phone: +31 20 5304488 ** fax: +31 20 5304499 ** http://www.terena.nl/ ** Please note telephone and fax numbers -------- Logged at Tue Feb 24 12:42:31 MET 1998 ---------
Niall & tld-wg, [Thanks for forwarding the message - not sure why my own attempt didn't work..] I am under the impression that late comments to the Green Paper might not have much impact but there is now also a proposed "rule" which the Dept. of Commerce have published. Being ignorant of US governmental procedures, I dont know what the exact process nor its implications are, and there seems to have been some doubt expressed (on the IETF list - so it could be nonsense) as to the legality of this move. I dont know. (Actually, if someone here knows the definitive ruling on this, I'm sure the tld-wg would be interested in knowing.) However, it appears that this is gathering momentum. The proposed "rule" can be found at: http://www.ntia.doc.gov/ntiahome/domainname/022098fedreg.txt and I understand that there is about a month left on which to comment on this. I dont propose to start a parallel discussion here but my question to you guys is whether or not you think it might be useful to formulate a combined response from the European TLD administrators community / ISP community? I know some of you have met with Magaziner privately - do you believe he took your comments on board? (Again, I admit ignorance.) Do you think they will listen to comments from outside the US? Is the proposed rule a Bad Thing or a Good Thing, in your opinion? Does it affect us at all (since most of use country-level TLDs)? Do we care? John John Martin TERENA, Singel 466-468, NL - 1017 AW Amsterdam phone: +31 20 5304488 ** fax: +31 20 5304499 ** http://www.terena.nl/ ** Please note telephone and fax numbers -------- Logged at Tue Feb 24 13:07:52 MET 1998 ---------
[CCs clipped a bit]
I am under the impression that late comments to the Green Paper might not have much impact but there is now also a proposed "rule" which the Dept. of Commerce have published. Being ignorant of US governmental procedures, I dont know what the exact process nor its implications are, and there seems to have been some doubt expressed (on the IETF list - so it could be nonsense) as to the legality of this move. I dont know.
I think that it is more sensible to see the references to US law as defensive measures. Ira Magaziner cannot move unilaterally; he has to have some justification for his actions. Given the context in Washington, in which special prosecutors are appointed at a moment's notice, this is understandable.
and I understand that there is about a month left on which to comment on this.
The comment period ends on 23 March. Then there is talk of another proposal being issued in June.
I dont propose to start a parallel discussion here but my question to you guys is whether or not you think it might be useful to formulate a combined response from the European TLD administrators community / ISP community? I know some of you have met with Magaziner privately - do you believe he took your comments on board? (Again, I admit ignorance.) Do you think they will listen to comments from outside the US? Is the proposed rule a Bad Thing or a Good Thing, in your opinion? Does it affect us at all (since most of use country-level TLDs)?
It certainly has bad elements in it. While I can understand why Magaziner is citing a legal basis for his actions, they would seem to act as a precedent for claiming that large and important parts of the global Internet are subject to US law. Specifically there is a suggestion that this includes the nTLDs: if the root is subject to US law, then US law can determine who controls the nTLDs. For openers, the registry requirements in Appendix A really ought to be applied to the nTLD registries, shouldn't they? Also, Network Solutions is being allowed to keep its monopoly control over the existing gTLDs (.com, .net, .org) and monopolies aren't good for anyone.
Do we care?
We certainly should. -- Jim Dixon VBCnet GB Ltd http://www.vbc.net tel +44 117 929 1316 fax +44 117 927 2015 -------- Logged at Wed Feb 25 15:40:57 MET 1998 ---------
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