[Newgtld-input] Input for applications ".vlaanderen" and ".brussels" with regard to "input on gTLD Batching"

Fri Aug 17 13:10:02 UTC 2012

Dear Sir and/or Madam

Please find below the point of view of DNS Belgium the applicant for
.brussels and .vlaanderen.

1.    Should the metering or smoothing consider releasing evaluation
results, and transitioning applications into the contract execution and
pre-delegation testing phases, at different times? 

We consider the release of the evaluation results at different times to be
a good approach. There is no valid reason why the publication of the
evaluation results should be extended till all applications have been
evaluated. This would mean that applications that are not contested and
that are successfully evaluated would be held back by those applications
that are more problematic. Regardless of the timeline for further
processing of the applications after the initial evaluation, it would be
detrimental to keep applicants unaware of the fact that their application
was successfully evaluated just because not all applications have been
evaluated. We also think that the next stages for the handling of the
applications can start once they have past the evaluation. This would help
smoothing the whole process towards delegation. Starting the following
stages only after all evaluations have been concluded and published would
create unnecessary and further delays for applicants that have an
uncontested string and managed to introduce a complete application file.
We would however keep the processing timeline identical for applications
(as long as they are not contested or don't need extended evaluation etc.)
that have been filed by the same applicant. It would be hard to explain
from a legal point of view that the application for .xyz is treated
differently from the application for .abc if both applications were
introduced by the same applicant and are nearly identical (scope,
financial framework and technical setup).       

a.     How can applications be allocated to particular release times in a
fair and equitable way?

ICANN should consider a simultaneous delegation process that allows
applications from the different regions to be added to the root zone
within the same timeframe. While this is perhaps more advantageous for
those regions that have introduced fewer applications, it is certainly not
disadvantageous for the American and European regions. It would certainly
add a picture that the new gTLD program truly is global and international
in nature. 

At the same time, we think that applications that can demonstrate a public
interest (geographical applications, community based applications and IDN
applications) should be handled prior to more generic applications. The
first mentioned type of applications can demonstrate by their nature that
they serve an already clearly defined community while this is less evident
for generic applications. We also think that the risk for objection or
string contention is less likely for those applications than for the more
generic ones.  

b.    Would this approach provide sufficient smoothing of the delegation
rate?

While we cannot predict whether our proposed approach would be enough to
eliminate all potential timeline issues, we are convinced that it will
help smotthing the whole process and is a far better alternative than just
releasing one single batch of result after the initial evaluation of all
applications.  

c.     Provide reasoning for selecting this approach.

We think that ICANN should maximize its efforts to achieve an efficient
handling and continuous processing stream of applications while preserving
global diversity and particular attention for public interest. In that way
future registrants across the globe will see the benefit of the existence
of new gTLD's to its fullest potential.  

2.    Should the metering or smoothing be accomplished by downstream
metering of application processing (i.e., in the contract execution,
pre-delegation testing or delegation phases)? 

We believe that the proposed approach as described above would seriously
limit the risk of having a congestion in the post evaluation stages.
Certainly for applications with public interest there would not be a need
for downstream metering. It could be possible that a downstream metering
is appropriate for the more generic applications. As the applicant for two
geographical names, we feel it would be inappropriate to express ourselves
concerning the downstream metering of generic applications. However as a
general principle we refer to ICANN's global mission and would advise to
what we stated above concerning the fair and equitable processing of
applications from the different regions. 

a.     How can applications be allocated to a particular timing in
contract execution, pre-delegation testing, or delegation in a fair and
equitable way?

As the applicant for two geographical names, we feel it would be
inappropriate to express ourselves concerning the downstream metering of
generic applications. However as a general principle we refer to ICANN's
global mission and would advise to what we stated above concerning the
fair and equitable processing of applications from the different regions.

b.    Provide reasoning for selecting this approach.

See answer provided previously to similar question.

3.    Include a statement describing the level of importance that the
order of evaluation and delegation has for your application.

We think that a lot of valuable time already has been lost and would like
to see that ICANN puts a particular focus on not creating any further
delays with the delegation process for new gTLD's. For both our
applications (.vlaanderen and .brussels) time is becoming a crucial
element. The order of evaluation is important but less critical than the
ultimate timing for delegation of the extensions. Both the Flemish and
Brussels Governments have already indicated that the start of the
registrations (or at least the sunrise phase) should begin before the end
of Q1 2014. 

For further clarifications or questions.

Kind regards

Philip Du Bois

General Manager

+32 16 28 49 70

+32 497 51 40 31 

DNS Belgium vzw/asbl

Ubicenter . Philipssite 5, bus 13 . B-3001 Leuven

 <http://www.dns.be/> www.dns.be

Description: Beschrijving: cid:5682F95C-155D-41DA-BB84-DF0FE48CD348

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