Applicant Guidebook comment period update

by Kieren McCarthy on December 22, 2008

The first comment period for the Applicant Guidebook has now closed for English speakers, and will close on 7 January for those responding in Arabic, Chinese, French, Russian or Spanish.

The responses sent in will now be carefully compiled and summarized. In the New Year, this summary will be published and soon thereafter, suggested alterations to the Guidebook based on that feedback will be put back out to the community.

The revised Guidebook will then be put out to a second comment period in order to enable fine tuning.

As of Monday 22 December, this first public comment period has received 317 comments through its dedicated online forums. Respondents come from 24 different countries and each of the five global regions.

Respondents were given the option of responding to the Guidebook as a whole, or individually to one of the six modules that makes up the Guidebook. Just over half (55 percent) chose to comment on the Guidebook as a whole; the remainder (with a small overlap) made specific comments about the modules.

Of the modules, the fifth module, covering the legal agreement between new registries and ICANN received the most comments (43 of 141, or 30 percent). That was followed by Module 1, which covered, among other things, the costs of applications: it received 32 comments or 23 percent. Thereafter, evaluation procedures (17 percent); dispute resolution (13 percent); string contention (12 percent); and terms and conditions (5 percent).

We look forward to continuing the conversation and revision process in 2009.


{ 12 comments… read them below or add one }

George Kirikos 12.22.08 at 5:00 pm

As per the letters from the US Department of Commerce and the Department of Justice, ICANN should refrain from putting out a revised guidebook until the relevant economic studies are completed and digested by the community. At that point, the community can decide whether the new gTLD process should proceed or not, and if so, how.

David Wrixon 12.24.08 at 6:52 am

It would seem that the way forward in the short-term is to prioritize those extenions that don’t actually require any new registrations.

There is absolutely no reason not to roll-out IDN gTLDs that are linked (can only belong to the same registrant) as existing ASCII domains, whilst the debate over the future of additional ASCII extension rages. As the latter seems to be going to rage for some time, it would seem that this is the only way to salvage the process along with ICANN’s reputation.

Failure to do this is likely to end up with a situation where nobody will be able to provide the Internet with the leadership it needs in the short to medium-term, and certainly not ICANN.

The DOC might try to pull things out of the fire by taking control, but in reality they would struggle to secure little more than a sorry localised rump of a hitherto grand scheme. Not providing the wider World with the name infrastructure it needs can only result in an unmitigated disaster and do immeasurable damage to World Trade. But then again perhaps that is now part of the agenda.

gpmgroup 01.01.09 at 5:59 am

ICANN is an amazing participatory global multi-stakeholder organization which truly deserves to survive, but one has to wonder what will happen in September? How could such an ill considered and poorly drafted key proposal document for underpinning the very future of the Internet, ever have been allowed to see the light of day?

It is almost as if elements that should have known better have been mesmerized by their own glossy marketing materials “for a major initiative that will transform the Internet”. The whole Draft Applicant Guide Book and associated documents smack of an extremely rushed process from a committee captured by vested interests, rather than a well considered proposal for improving the Domain Name System as a whole.

Whilst it is good to have important draft documents out for public consideration as early as possible, the lack of thought and foresight on the most basic of matters is, quite honestly, astounding.

The number of, and depth of important issues raised by such major corporations, organizations and governments whose day to day business isn’t anything to do with the workings of the DNS illustrates just how weak and fundamentally flawed the thought processes are which have gone into preparing theses draft proposals.

The letters from the DOJ and the DOC (18th, Dec, 2008) begin to touch on some of the problems and I think the GNSO and ICANN as a whole, would be well advised to consider what they are both saying very, very carefully.

Kieren McCarthy 01.05.09 at 9:57 am

@ George: We have of course noted the letters from the US government and that input will form a part of the input into the process. Unfortunately you have rather mischaracterized what the letters actually say so there’s not much more I can say in response.

@ David: I think you are jumping a little ahead here wrt ASCII gTLDs. The whole point of having a public comment period is for people to raise their concerns and for ICANN to make changes as a result. That was always the plan and the timeline accounts for that. So it’s a little premature to be worrying about what will and won’t happen. The plan as we enter 2009 is the same as it was in 2008.

Short answer: we are pretty confident that IDNs will go live for the first time in 2009.

@ gpmgroup: There’s a lot of emotive and over-the-top language in your comment which makes it difficult to respond to. But it is worth noting that the new gTLD process is very far from news for anyone involved in the Internet’s infrastructure – there have been years of discussions on this. What really would have been surprising is if everyone was in agreement during the first public comment period.

This is a complex process and what we appear to have heard from the first comment period is that one of the stakeholders in this process – business – has concerns and wants changes. Great. There has been a lot of careful balancing of interests to get to this point; it was never going to be 100 percent right – which is why not one but two public comment periods have been written into the process.

So we do what a multistakeholder body does and try to address those concerns while also keeping all the other stakeholders on board and in agreement. It’s not exactly the first time that this has happened with regard to changes to the domain name system. This careful balancing is what ICANN does; what it was created to do.

Oyun 01.05.09 at 9:04 pm

thanks for you..!

gpmgroup 01.07.09 at 2:45 am

I don’t think it would be over-the-top to say ICANN has been gifted the management of one of the most elegantly designed and most successful systems in the history of mankind.

I also don’t think it would be over-the-top to say that with that gift comes an inordinate amount of responsibility and in order to fulfill that responsibility ICANN needs people on its committees who are truly selfless.

Given the magnitude of the effects from the changes being proposed the rushed nature of the process is extremely worrying.

The Draft Applicant Guidebook was late and incomplete. Its lateness means the GAC is not able to provide substantive comments and do not expect to be able to do so until the Mexico meeting in March 2009. The European Commission advises it wishes to communicate with ICANN on new gTLDs through the GAC.

It is time consuming for individuals not working full time on any complex document to provide detailed objective submissions. The current economic climate means many individuals have to concentrate on generating revenue to survive or ensuring the companies they work for survive. (This is reflected in many areas and the level of traffic to various technical internet discussion forums has been significantly diminished for the last 18 months or so.)

All of which may explain why a higher than expected percentage of the total comments are from large corporations which have the resources to comment in sufficient depth on a complex draft document.

The DOJ and the DOC did however manage to submit substantive comments via letters to ICANN shortly after the public comment period closed. The issues they both raise are fundamental.

The DOJ suggests new gTLDs as proposed by the current draft are unlikely to help ICANN meet its obligations under the MOU/JPA.

DOC letter questions the lack of the economic study and report requested by the ICANN Board 18th October, 2006 and they suggest ”ICANN needs to complete this economic study and the results be considered by the community before new gTLDs are introduced”

Compare and contrast this with what is going on inside the GNSO. For example: Thursday’s meeting (8th Jan, 2009) there are two motions on [new] gTLD Implementation.

The first motion is looking to shorten the process by running a 4 month Communication Period from the early March Mexico Meeting come what may. (i.e. Seeking to change the original proposal of allowing at least 4 months after the Final RFP has been published for promoting the opening of the application round.)

The second motion seems to be trying to tie the deployment of new IDN gTLDs to Fast Track IDN ccTLDs.

Kieren McCarthy 01.07.09 at 5:08 pm

@ gpmgroup: I previously said that it is hard to respond to comments that are over-the-top.

Words such as “mesmerised”, “lack of thought”, “weak”, “fundamentally flawed” – these are over-the-top for the simple reason that they do not in any way reflect reality. The truth is, I am afraid, very much duller: you work through issues, you take feedback, you make changes, you take more feedback, you strike a compromise, it is done.

I know that in earlier days ICANN was a hot-bed of passionate argument but the reality is that the organization has grown up a lot in 10 years and arm-waving argument is no longer accepted as an alternative to reasoning. A five-minute treatise at a public microphone is good theatre, but a carefully thought-through paragraph emailed to a public comment period is 1,000 times more effective.

A large number of comments recently – though fortunately not many of those actually submitted to the Applicant Guidebook public comment period – have been focussed purely on providing criticism of ICANN without an underlying or coherent argument attached.

So, for example, in your comment above, you complain that the process is both too slow and too fast. Now, while some community members say it is too slow (the GNSO, commenters in the public fora, potential applicants) and others say it is too fast (the GAC, the USG, various respondents to the comment period) – the problem is that you complain it is too slow and also complain it is too fast. That’s just complaining.

Look at it through the eyes of ICANN staff: there are a range of different views and perspectives, many of them contradictory to one another. Somehow a path forward has to be found and so what you do is follow the threads of logic: *why* do you think it is too fast? It’s not because there is a belief that such a process should always take x amount of time; it’s mostly because they are issues that they believe are not right but which can be sorted out if there is more time devoted to them.

If you can get at those issues and find solutions to them, then the fear of going too fast can be alleviated.

That is just one construct; the point is that it is not so much the headline argument that you need to pay attention to but what is behind that argument. If you can draw out all of the different issues underlying the problem, you can start to find solutions.

Now, the problem with what I call “scattergun criticism” is that there is no philosophy or underlying thought running through the comment – the comment exists purely as a demonstration of criticism. In many cases, the criticism sounds reasonable because it repeats what others have already argued, but there is nothing behind it – nothing that can be worked on. In short, it is a comment for which there can be no useful response.

So, while it no doubt gratifies you – and many others – to point out where the problems are, and occasionally suggest changes to fix them, these comments provide no route to solving the problem. As such, they have very little relevance to the ICANN process and as a result tend to be ignored by both the staff and the community who are too busy focussing on more valuable responses.

The only reason that I respond, as general manager of public participation, is because I believe that ICANN needs to embrace openness as far as possible in order to keep any barriers to participation as low as possible.

I also think that in some cases the anger directed at ICANN demonstrates someone with a willingness to get stuck into the detail – and it is people such as this that are extremely valuable to the whole ICANN process. It is also important to keep checking that those angry, seemingly pointless comments are not actually the results of frustration at not being able to get a more serious point across.

I hope that answers your question, if not directly, at least in a broader sense.


gpmgroup 01.14.09 at 1:43 pm

Kieren, sometimes it’s useful for any organization to see an external perspective on things. We have followed the ICANN process for many years and admire the way ICANN has often managed to navigate between, at times, divergent interests. As a consequence of ICANN’s skillful navigation we have also watched the various affected parties cry foul.

When I make a comment on a process like new gTLDs I am always very mindful to put any personal interest aside. Sure most people would like certain things to happen but to lobby for changes to an extremely successful existing system purely for self interest is not right under any circumstances.

It is wrong of you to try and portray my comments as arm waving and criticism for criticisms sake, my words were carefully chosen to reflect how I and judging by many of the comments on new gTLDs, many others, are extremely concerned by the way the new gTLD process has been allowed to evolve. Equally concerning is that several elements within ICANN appear on the surface at least, to be prepared to try and carry on regardless, simply dismissing these concerns as being predominantly from a single self-interested lobby group.

You were also very wrong to mischaracterize my statements as saying the process was “too fast and too slow”.

I did not say that. I pointed out it was late (fact) and also pointed out I believe the process is rushed, evidenced by the fact that the GAC has not had time to comment and the USG was not able to comment before the initial end of the comment period. A comment period which incidentally was, for what ever reason, ridiculously short and messily extended.

The comment periods are also too close together so it is likely Governments will still be trying to consider the first draft while the second draft is being prepared and published. This is not only confusing and time consuming it also shows a willful disregard for other people’s time and resources.

Given the serious nature of changes new gTLDs as proposed may bring to one of the most successful systems on earth the undue haste is extremely worrying. So what if it takes an extra six months or a year even? – It is too important to not to get the deployment right.

As indicated expanding the namespace with new gTLDs is I believe likely to have serious and far reaching implications which certainly need to be articulated and considered by the wider community, rather than presented to them as a fait accompli.

This approach goes against the very founding principles of ICANN. Producing a marketing tag line like “Openness Change Innovation” is not a substitute for a process derived from consensus policies. Saying the process has been discussed inside ICANN for years just doesn’t cut it either.

ICANN has a responsiblility to articulate the benefits of new gTLDs and present independently produced reports and studies which clearly substantiate the likely social and economic benefits whilst at the same time clearly consider all the possible and likely social and economic impacts of introducing new gTLDs to the wider community.

Once this has been thoroughly discussed by the wider community the feedback should be used to produce an options document to present the best methods for the delivery of new gTLDs.

Once there is consensus on how new gTLDs should be introduced, then and only then should ICANN produce implementation documents asking the wider community to dot the i’s and cross the t’s.

Asking people to comment on what I believe to be incomplete and fundamentally flawed documents at this late stage in any process is quite frankly embarrassing, and certain people should have known better because I believe it casts ICANN as a whole in a very bad light.

Finally, Kieren, believe me I take no gratification in taking time to point out what I believe to be failings on such fundamental issues. New gTLDs are a complex issue and to be blindly for or against is very telling. Take .xxx as a nice emotive example. Even before the ICANN Board considered .xxx it was obvious that the wider world outside ICANN would never agree to allow .xxx to be implemented.

Simply because .xxx by definition draws two arbitrary boundaries; what’s not titillating enough and what’s too extreme even for .xxx. Obvious problems arise because every individual has strongly held beliefs of where they personally feel those two boundaries should be drawn, and worse many feel their personal view should be the one everyone else should use.

What happened with .xxx illustrates why it is so critical to get the new gTLD process right and why I believe you have to have truly selfless people on the committees making the correct process decisions. Continue to get it wrong and ICANN as an organization is setting itself up again for a battle I believe it is unlikely to win.

Kieren McCarthy 01.14.09 at 3:49 pm

Thankyou for a more reasoned and reasonable response Gpmgroup.

What I do need to note is that there has never been any suggestion beyond people’s over-active imaginations that comments on the Applicant Guidebook will be in any way dismissed.

In fact, the public comments are being used as the driver behind virtually all discussions going on internally for reviewing and revising the Applicant Guidebook.

What is also slightly unreasonable in your response is that you now feel that the entire process needs to be re-evaluated. ICANN shouldn’t have released an implementation plan (which is what the Applicant Guidebook is) until some new undefined approval process was gone through, you suggest.

But the approach taken was what was agreed through the ICANN process. It is what the GNSO suggested; it is what the Board approved. And at every major step, that process was open to the community to raise their concerns and their points.

Now, I know that it is only natural that most people do not wish to participate at every step in a process. And of course there is always greater interest when something is final or almost-final. But the cost of taking that approach is that along the way decisions are made that you cannot undo.

Now if you feel you were not able to participate, or that you were in some way unaware that you could participate – well, then that’s what my job is, and I would be interested in hearing any concerns you have. ICANN has to strike that difficult balance between making progress and also allowing people to effectively review the work done so far. You allude to this in your comment about the length of comment periods – a topic that is going through a lot of discussion at the moment.

But that aside, the important point is that the Applicant Guidebook is predominately NOT a fait accompli as you suggest. It is out for public comment. And it will go out for a second round of public comment after the first round of public comment. The Guidebook is in fact the complete opposite of a fait accompli.

What is probably of most use to you at the moment is a link to an announcement ICANN put out on this process a few days ago. You can read it here:

In that response, the main concerns are pulled out and Paul Levins (ICANN’s VP of Corporate Affairs) makes clear that: “There is no doubt that we need to address these and other legitimate concerns before proceeding to open the application process.”

So, arguments aside, if what you wanted was an official quote explaining to people that ICANN will not open up applications until we have addressed legitimate concerns, then there you have it.

So can please stop this talk of battles, willful disregard, dismissing concerns and all the other groundless accusations thrown at ICANN staff in the past few weeks. There is alot of work to be done and we are doing it. And more than anything we need the community to work constructively with staff on finding solutions to the issues raised in the first comment period.



Kit 02.16.09 at 1:54 am

Can i download at least older versions of the book by means of ? I badly need them for my work!

hakan 07.14.09 at 3:02 am

really nice work and comments

GreatMan2 11.20.09 at 6:02 am

good work , nice note , respect!

Leave a Comment

You can use these HTML tags and attributes: <a href="" title=""> <abbr title=""> <acronym title=""> <b> <blockquote cite=""> <cite> <code> <del datetime=""> <em> <i> <q cite=""> <strike> <strong>

To prove you're a person (not a spam script), type the security word shown in the picture. Click on the picture to hear an audio file of the word.
Anti-spam image