SRS Implementation Green Paper Submission J Carter
SUBMISSION to the Green Paper on the Implementation of the SRS.
Jordan Carter - ISOCNZ Councillor & Member.
March 2001
Introduction:
1. This submission sets out my views on the key topics outlined in the Green Paper where I have an opinion. It then makes a few comments about how ISOCNZ can contribute to a satisfactory outcome, and how ISOCNZ itself can continue to operate in the future. It is not intended to be an extensive submission or to cover all the areas that could be discussed.
2. The general context of my submission flows from the view that ISOCNZ, as the holder of the .nz ccTLD, needs to ensure its control over that monopoly imposes costs as low as possible. That is, the .nz TLD should be administered in a financially responsible manner as a public good monopoly, as far as its Registry is concerned, with competition between Registrars providing good services at low cost to registrants in a variety of ways. This is the thrust behind the original SRS WG Report as issued on 20 October 2000, for which I wish to record my support, endorsement and appreciation.
3. ISOCNZ carries out,.
3. ISOCNZ carries out, and should continue to carry out, a range of public good functions. The ccTLD manager requires funding from the Registry. My view is that there is also a justifiable case that ISOCNZ's own operations should continue to be funded by the Registry as well, in a manner to be explained below.
Removing the Registry from the Company:
4. While it is tempting to argue that an entirely clean slate is needed, it is hard to ignore that what expertise there is in New Zealand when it comes to running a Registry (albeit fairly badly) lies within NZIRL. Therefore it would seem to me that the company must be a key part of the creation of the new Registry.
5. The above does not imply that NZIRL should continue to hold the Registry. Rather, I see NZIRL providing full access, premises (if required) and cooperation to the SRS Implementation Manager and team to construct a new Registry in a separate organisation. My concern is that NZIRL must be a full and cooperative partner in such a process.
6. Once the split is complete, the Registry will be a separate entity. NZIRL will continue to operate as a Registrar.
7. NZIRL, as the Society's operating arm, should be required to provide all necessary operating and capital resources for the creation of the new Registry. It must manage the provision of such resources (in the quantum already discussed in the Budget for 2001in the Budget for 2001-02) while ensuring that it remains able to offer its current services. This will be discussed below.
8. Without addressing the list of questions supplied in this area (sections 5.9-5.11), legacy services must be provided by NZIRL, because it makes no sense to lumber the new Registry with the mistakes of the past. As far as possible, the SRS Registry should be a clean break with the past.
9. The business model for the Registry should be that of a non-profit entity. The Registry should cover all its costs and supply ISOCNZ/ccTLD Manager with resources that are adequate for their needs, and should not be used as a means to extract excessive resources from Registrants. The pricing model should be one that supports large-scale Registrars as the prime clients of the Registry, and discourages self-Registrars. This is to reduce transaction costs, financial and security risks that may arise from maintaining links with a large number of self-Registrars or other small organisations.
Ownership of the Company as a Competitive Registrar
10. ISOCNZ should not, as a matter of principle, own a competitive Registrar in the long term. It would clearly be a conflict of interest with our control of the SRS.
11. ISOCNZ should retain ownership of NZIRL as a Registrar past the transition stage of the SRS until selling it as an going concern poses little threat to the competitive nto the competitive nature of the Registrar market. This is outside the commitment mentioned in paragraph 8 above for NZIRL to maintain legacy interfaces.
12. I would think that the conditions for acceptable sale of NZIRL would be not fewer than six months after the SRS goes live; there are at least five Registrars; and that NZIRL is registrar for fewer than 60% of the domain names in the Registry. [cf Green paper suggestions of six months, five Registrars, < 75% of names.] I am concerned that having 3/4 of names with one Registrar would simply see ISOCNZ selling a market-dominant firm out of pseudo-public control into the private sector, and leaving it with too much power. We don't yet know how likely Registrants will be to change Registrars, and until we do, we can't say whether NZIRL will be too powerful in the private sector or not. If this remains a problem, we can consider requiring NZIRL to stop accepting new clients until its market share falls below 60%.
Obligations of the Company during the transition
13. The contractual relationships the Company has with accredited .nz service providers, resellers and Registrants must be retained in full as long as those other parties wish to maintain them. That said, NZIRL should strongly encourage .nz service providers and resellers to become Registrars in their own right under the SRS, so it can focus on providing services to Registrants as its core business.
14. The point in 7.1.4 relating to ensuring NZIRL gains no unfair advantage in the rollout of the SRS will be very difficult to ensure. If, as I believe is required, NZIRL plays a role in the creation of the Registry, then there is going to be some crossover. NZIRL must be given the same access to the new system as every other player, however, and cannot be allowed to gain any "inside" knowledge that can realistically be withheld from it.
Obligations of the Society during the transition
15. The Project Manager for implementation should be based at the Society's offices, and report to Council through the Executive Director for day-to-day management purposes. The policy to implement the transition to the SRS should be drafted by the Project Manager and then developed by the SRS IOC before being adopted at a specific Council meeting. The manager should be hired as soon as possible and be a key part of drafting the White Paper.
16. Sections 8.8-8.12 make sense. Under no circumstances can we allow a situation to develop where the media or anyone else gets word of Registrants being trapped by Registrars.
Managing the process of transition
17. The Green Paper outlines a tremendous work programme for the IOC, especially with regard to the detail of the split of the Registry from NZIRL. In my view, therthe Registry from NZIRL. In my view, there is scope for this work being devolved to a number of WG's including all interested Council members. Speaking personally, I would like to be more involved with the process but have not had an opportunity to yet do so. It may be useful to keep the focus of the SRS IOC on the management of the Project Manager/Implementation Team, and as an oversight group for the rest of the process. A subsidiary WG could be useful to manage the policy development process, and another to look at the future of NZIRL in more depth. I just don't want to see us overloading the SRS IOC and thus having delays generated by an overloaded committee.
18. ISOCNZ should be more concerned that the SRS is implemented without mistakes, than that it is implemented within a given time frame. I have found the time taken to get the process to this point fairly frustrating, but we are at the point now where the process is in place to implement, and unneeded haste here will simply be counter-productive. Council at this year's AGM needs to report substantial progress, but should not expect to have completed the SRS by then.
Resourcing ISOCNZ in the future
19. It is generally accepted, I think, that most costs are associated with the ccTLD manager. ISOCNZ can provide some services (eg policy) to the ccTLD manager to obtain some funding. Yet, as the overarching holder of the .nz ccTLD, it seems to me that the Society has some right to call on registrants to contribute to its resources.
20. The Society must ensure that such resources are limited, are used in a publicy accountable and transparent manner, and are not spent on frivolous activities. They should maintain the existing ISOCNZ staff and allow it the resources to perhaps hold the Secretariat functions for one of the international organisations; allow ISOCNZ Council to function; and allow ISOCNZ to maintain some public good functions (eg summits, roadshows, seminars, submissions etc).
21. The sum needs to be discussed, but I would think that ISOCNZ expenses (as opposed to ccTLD Manager expenses) should be constrained to a sum less than $4.00 per domain name per year.
Conclusion
22. By the time the SRS implementation is finished, .nz should be a top-class TLD with a robust Registry providing professional services to a wide range of Registrars who deliver to Registrants the service packages they desire. NZIRL should be sold, providing substantial funds to ISOCNZ (with their use outside the scope of this paper!). Once this is achieved, the Society should be able to leave most of the .nz issues to the ccTLD manager, and focus on its broader mission.
