Personal tools
You are here: Home Proceedings Task Force Proceedings Archive wg-domainz-model-review Draft Report 02/06/00
Navigation
 

Draft Report 02/06/00

Review of Registry Structure of the .nz ccTLDReview of the Registry/Registrar Framework for the .nz ccTLD

Document Status

Published 19 May. This report went to Council for comment at its meeting of 26 May.

Executive Summary

This Working Group was established under the authority of the Internet Society of New Zealand to review and make recommendations on the framework within which the Domain Name System for the .nz ccTLD is administered and managed. Having received and considered input from and consulted with the New Zealand Internet community the Working Group makes the following recommendations.

Recommendation 1 . That ISOCNZ adopt a Shared Registry Model for administering the DNS within .nz. This should be implemented by removing the Registry function from Domainz and maintaining Domainz as a Registrar.

Recommendation 2 . That ISOCNZ establish an Implementation Team consisting of representatives of appropriate Council Committees and Working Groups, an industry representative and contracted project manager to oversee the transition.

Recommendation 3 . Requirements to become a Registrar should be minimal: a legal entity willing to sign its contract and pay its invoices.

Recommendation 4 . The charging regime use by the Registry should be as neutral as possible, reflecting the Registrars use of the Registry. A monthly charge should include a fixed or minimum component equivalent to approximately 100 names.

Recommendation 5 . The information held in the Registry for each name should be that information required for the correct operation of the DNS, identification and authentication of both the responsible Registrar and the Registrant, and technical and administrative contacts for the name.

Recommendation 6 . ISOCNZ should establish policy setting standards for the governance of the .nz portion of the DNS. This policy should be enforced through contracts.

Recommendation 7 . ISOCNZ should adopt a Statement of Best Practice. This statement should be instrumental in the governance of the Registry and in the development of working relationships with Registrars.

Recommendation 8 . A standing committee should be established to maintain liaison between ISOCNZ, the Registry and the Registrars.

Recommendation 9 . ISOCNZ should consult with its legal advisors with a view to establishing a method for funding DNS policy development that is fully transparent and subject to annual approval of the membership.

Mandate

Within New Zealand responsibility for the .nz domain name space rests with the Internet Society of New Zealand. The Objects of the Society include:

  • To promote the competitive provision of Internet access, services and facilities in an open and uncapturable environment;
  • To develop, maintain, evolve, and disseminate standards for the Internet and its inter-networking technologies and applications; and
  • To coordinate activities at a national level pertaining to good management of centralised systems and resources which facilitate the development of the Internet, including but not limited to the Domain Name System;

At the Society's AGM held in December 1999 a motion was carried:

  • That ISOCNZ Council set up an open working group to investigate a full proposal on possible shared registration systems and other registry models after consultation with Domainz.

The working group was established at the Council meeting of 31 March 2000. The membership of the Working Group was:

  • John H. Hine, Victoria University of Wellington (Chair)
  • David Farrar, Office of the Leader of the Opposition
  • Steven Heath, SeraNova
  • Rick Shera, Lowndes Jordan Barristers & Solicitors
  • Don Stokes, Independent Consultant
  • Peter Dengate-Thrush (ex-officio) Chair of ISOCNZ
  • Sue Leader (ex-officio) Executive Director of ISOCNZ

David Farrar resigned from the Working Group on 18 April and Peter Dengate-Thrush withdrew on 19 April 2000.

Definitions

The Domain Name System (DNS) is the system used by the Internet to translate domain names such as isocnz.org.nz into network addresses that allow one computer to connect to another. There are approximately 250 top-level domains. The majority of these are country code top level domains, ccTLDs . These names all use the two level ISO-3166 standard abbreviations for country names. There are also seven generic top level domains, gTLDs . Ideally these would all be international in nature. For historic reasons some such as .org and .com are and others are focused on the United States.

In discussing the roles that are found in the management and operation of the DNS the Working Group has chosen to adopt terminology already broadly accepted in the Internet Community.

Registrant
An entity with rights to the use of a domain name within the .nz name space. (Current practice within New Zealand also often refers to the Registrant as the Name Holder.) Register The central database holding all information required by the Domain Name System, and possibly additional data, for .nz. The Register is the authoritative source for the creation of the primary zone files for .nz.

Registry
The organisation holding and operating the Register.

Registrar
An entity that registers names with the Registry on behalf of Registrants.

Agent
An entity that registers names through a Registrar on behalf of Registrants. An Agent is usually differentiated from a Registrar on the basis of indirect access to the Register compared with a Registrar's direct access.

Terms of Reference

The terms of reference of the Working Group as resolved by the Council of ISOCNZ on 31 March 2000 were:

  1. Ascertain the requirements and views of the New Zealand Internet community with respect to the appropriate framework for a shared registration system including the rights, responsibilities and relationships among the Registry, Registrars and Registrants.
  2. Determine any constraints placed on a shared registry system by any RFC or other national or international convention applicable to the .nz name space.
  3. Recommend to the ISOCNZ membership new and/or revised policy on a shared registration system including:
    1. Rights, responsibilities, obligations and duties of Registrants, Registrars and the Registry.
    2. Any limitations that should be placed on the business or technical relationships between Registrant/Registry, Registrant/Registrar and Registrar/Registry.
    3. Any quality of service performance requirements that should be placed on the Registrars, Registry and/or Registrants.

Background

ISOCNZ was established in 1995 to maintain a degree of "public good" control over the development of the Internet in New Zealand. This included the operation of the Domain Name System (DNS). At the time the University of Waikato managed and operated the Register. Both the University of Waikato and Victoria University of Wellington accepted new registrations, each looking after a different set of second level domains within .nz.

ISOCNZ established a number of working groups and committees throughout 1996 and 1997 to establish policy governing the .nz ccTLD and to take over the management and operation of the DNS for .nz. The following summarizes the outputs of these efforts and the current situation.

    1. A company, New Zealand Internet Registry Ltd., was established to take responsibility for the day-to-day management of the DNS. NZIRL trades as Domainz. ISOCNZ retained the policy making role for .nz including the DNS.
    2. Domainz has progressively migrated the various components of the operation of the DNS from the Universities to itself. This migration will be complete in May 2000 when Domainz takes responsibility for the operation of the Register from the University of Waikato.
    3. Policy with respect to the development of the .nz domain name space was approved by the ISOCNZ Council in August 1997. See (link to document)  . This document is principally concerned with names within .nz.
    4. A policy document, DNS Administration within New Zealand , was developed and approved by Council in August 1997. See (link to document)  . This document envisioned NZIRL acting in the role of contract manager with much of the operational components of the DNS tendered to different companies. Tendering has not proceeded. Comment on the lack of progress with tendering can be found at  (link to document).

A further policy document is The New Zealand Domain Name Structure. See (link to document) . This document clearly states the "first come, first served" principal upon which names are allocated within all unmoderated 2LDs within .nz. The Working Group is unsure of the authorship and authority of this document which combines various ISOCNZ and Domainz policies.

The paper DNS Administration within New Zealand is current ISOCNZ policy and has provided the framework within which Domainz and ISOCNZ have developed DNS management and services. It states a set of values:

ISOCNZ views the following items as important when discussing the future provision of DNS services:

Of paramount importance is the continued reliability of the Internet.

We wish to ensure that the New Zealand Internet remains "open and uncapturable".

Consequently we wish to allow and promote competition in service provision as far as possible.

Areas where competition is not possible should be strictly delineated and put up for tender.

The document envisions Domainz operating a Registry function with Registrants having the choice of registering names directly with the Registry or through a value added agent such as an ISP. The analogy is with the insurance industry. This document predated the distinction drawn today between a Registrar and an Agent. The intent was further confused by tendering of the Registry operation to the University of Waikato, which placed Domainz in the role that is currently defined as a Registrar.

The Working Group considers it appropriate to consider both the performance of the current model and the performance of ISOCNZ and Domainz within the current model against both the objects of the Society and the values given above.

Concurrent with developments in New Zealand the international situation has also changed dramatically. Control of the generic top level domains that are not United States centric has been passed from the United States Government to the Internet Corporation for Assigned Names and Numbers (ICANN). ICANN is currently considering a proposal which would expand the number of generic top level domains.

To date ICANN has focused on the generic top level domains. Its impact on ccTLDs has been indirect. The two key issues are:

(a) ICANN has addressed the issue of the monopoly operation of the Registry for the gTLDs by developing a model for a Registry that offers no services to Registrants, holds minimal information in the Register and deals solely with accredited Registrars. This model or some variant may be appropriate for use in ccTLDs such as .nz.

(b) ICANN has required Registrars to make use of a dispute resolution procedure in situations where disagreements arise over the rights to the use of a name. To date the requirement to use this procedure is restricted to the gTLDs, however the intellectual property lobby would like to see that requirement extended to the ccTLDs.

Consultations, Submissions and Related Findings

The working group obtained input through forums held in Auckland and Wellington, conversations with individuals and written submissions. A complete list is attached as Appendix A . While the views expressed at both forums and in the written submissions were largely from individuals, the Working Group has no reason to doubt that they are representative of the New Zealand Internet industry and community as a whole. The following paragraphs discuss the key issues raised through this consultation process.

Ownership of Names . The community is united in support for the current policy that a Registrant's rights over their domain name(s) is paramount. The Registrant's instructions should always be followed in full whether issued to an Agent, a Registrar or the Registry.

Registrant Benefits . The system should be run for the benefit of the Registrants. The current system successfully and rapidly registers names. From May 2000 the cost of registration, which is currently not seen as an issue, will reduce.

Business Relationships . Registering a domain name is simple and the consequences should also be simple. Registrants do not want multiple contracts or invoices and other communication from a Registry they are unaware of. Registrants are confused about who to contact with problems. These multiple relationships also cause problems for Registrars/Agents.

The Domain Name Market . There is a developing market which is seeing a requirement for varied needs: permanent registration, short-term registration, parking, trustee registration (e.g. company start up situation). Potential Registrars include law firms acting on behalf of clients to register names in the same way that they incorporate companies online at the Companies Office on behalf of clients. The current "one model fits all" approach is inadequate; there is no single Registrar that is right for all Registrants.

Ownership of Register Data . The community asserts that the data held in the Register is not owned by any Registrar or the Registry. The data is held on behalf of the Registrants. The ownership of the Register itself (schema, software, etc.) is less an issue as long as the Registry is owned or controlled by ISOCNZ.

Monopoly and Competition . The role of the Registry for the .nz domain name space is a natural monopoly. The management of the monopoly operation should not have the potential to use its position to (1) artificially increase the price of a domain name; (2) reduce the range of services available to Registrants; or (3) hinder the development of Registrars or Agents making use of its services.

Best Practice . A Registry owned by ISOCNZ should operate in a manner consistent with ISOCNZ's stated objects. It is also a monopoly and as such should not fear competition or the risk of disclosure of corporate information. Rather it should operate in a cooperative manner to foster the broadest development of the Internet within New Zealand.

Combined Registry/Registrar . It is unfair to make other Registrars compete against a Registrar that controls the Registry. A single business performing as both a Registrar and a Registry has an obvious conflict of interest and is likely to focus on the Registrar business at the expense of the Registry business. The current situation is given as evidence of this.

An SRS Architecture . Several submissions proposed specific alternative frameworks for the DNS within New Zealand. While differing in some detail they were generally consistent in the major aspects of the architecture.

  • The Registry is the necessary monopoly. As such it should be minimal and should not constrain competition amongst multiple Registrars.
  • Registrars would directly update the Register through an interface provided by the Registry.
  • Registrars would be free to set fees and design services as they see fit.
  • The Registry should be run independently of any Registrar and on a cost recovery basis.
  • A "special case" must be made for moderated domains. Suggestions included a Registry function that would make moderation transparent to Registrars and Registrars dedicated to specific moderated domains.
  • The Register should contain relatively minimal information. The double storage of identical information in two databases should be minimised.
  • Any barrier to becoming a Registrar should be minimal.
  • The Registry should have a "technical" focus with an emphasis on providing robust and highly available services. There should be regular (e.g. weekly) liaison between the Registry and the Registrars to ensure a seamless operational interface.
  • The "customer" focus should be the responsibility of the Registrar. Registrants deal only with Registrars and/or Agents.

Registrant Rights . Both forums spent considerable time discussing how the rights of a Registrant would be upheld in a SRS model as described above. There were two key conclusions:

(a) The Registrant should always be able to confirm the information held in the Register about their name and themselves.

(b) The Registry must be able to initiate contact with the Registrant if for any reason the linkage through a Registrar becomes broken; for example, if the Registrar were to fail.

Policy . ISOCNZ policy making is valuable and should be paid for by those that benefit. With respect to the DNS the beneficiaries are Registrants and Registrars.

Change . Change always incurs a cost, however change to an interface used by several hundred organisations can incur considerable cost. If possible, the current interface should be preserved for a reasonable period.

The Key Issue

Domainz has been very successful in migrating domain name registration from a volunteer project at Waikato and Victoria Universities to a business.

  • It has registered approximately 60,000 names within the .nz namespace as of May 2000.
  • Its performance with respect to registration has been outstanding, indeed in terms of the efficiency of its registration system it justifiably claims to be a world leader.
  • It has successfully resolved issues such as the validity of the first come first served policy.

Despite the clear intent of ISOCNZ, as expressed in DNS Administration in New Zealand , to establish a minimal service representing the monopoly component of the DNS operation, Domainz has become a full Registrar. We do not believe this was intentional, but is rather a consequence of developments in the DNS since 1996. Today's definition of Domainz's role reflects a much greater understanding of the DNS business.

The present position of Domainz as a Registrar raises the core issues that must be addressed by ISOCNZ.

(a) Aspects of Domainz's current business model unnecessarily impinge on the business processes of its Agents. These include the annual registration and billing cycle and the business relationship that Domainz maintains with Registrants.

(b) To date Domainz's focus has been strongly on its name registration model, i.e. the Registrar component of its business. This has been to the detriment of providing a Registry interface for the use of other Registrars and to the network side of its system, the users of the DNS.

(c) On one hand Domainz has provided an excellent service to Registrants who are happy to register a name on a long term basis and, depending on the agent, make annual payments to Domainz for that registration. On the other hand the impact of Domainz's business model on its agents has inhibited the development of the alternative services that some registrants are seeking and confused others as to whether the Agent or Domainz is responsible for resolution of a particular problem.

(d) There has been broad based comment and complaint about Domainz's lack of consultation, particularly on technical interfaces. In summary, Domainz is not perceived as operating in a cooperative fashion designed to foster the development of the Internet.

The Working Group received input indicating that part of the community believed the current problems could be resolved by altering a number of Domainz's current operating principles. Other's believed these problems were endemic to a situation in which one Registrar with monopoly control of the Registry competed with other Registrars. The latter group argued that a new model is needed.

The Working Group concurs with the community that this is the key issue to be resolved. Other issues of detail can only be addressed when the overall architecture is decided. Considering the current level of investment in Domainz's systems; the likely impact and cost of a change to the Domainz interface currently used by Agents; and the range of input received from the community the working group has identified three viable alternative architectures.

  • (a) A single combined Registry and Registrar with all others acting as agents of the Registry/Registrar. Domainz would act as the combined Registry/Registrar. ISOCNZ governance would be required to ensure a range of services at an economic price to all Registrants.
  • (b) A combined Registry and Registrar providing both Registrar services and a Registry interface to other Registrars. Domainz would act as the combined Registry/Registrar. ISOCNZ governance would be required to ensure that Domainz did not take advantage of its control of the Registry to either assist its Registrar business or hinder other Registrars.
  • (c) A separate shared registry independent of any Registrar. ISOCNZ would operate or control the Registry. Domainz would continue to operate as a Registrar on an equal footing with other Registrars. Governance measures designed to put Domainz at arms length from ISOCNZ as the owner/controller of the Registry and policy maker will be needed to ensure this equal footing.

In the following table we have attempted to summarise the advantages to different stake holders of each of the above architectures. During our consultations it became clear that some organisations wished to become Registrars for the purpose of dealing in Domain Names while others would only become Registrars because of the likely efficiencies of registration. For this reason we have divided Registrars into two groups. The advantages for each stake holder are identified in the table by a characteristic identifier. Expanded explanations of each characteristic follow the table.

  Single Registrar
and Registry
Combined Shared Registry,
Multiple Registrars
Shared Registry
Multiple Registrars
Registrants Transfer, Privacy Choice, Single Contract Privacy, Choice,
Single Contract
DNS Marketers Stability, Transparency,
Fairness
Stability, Choice Stability, Choice,
Transparency
Fairness
ISPs, Web designers Stability, Transparency,
Fairness
Stability, Choice Stability, Choice,
Transparency
Fairness
Domainz Continuity, Profitability,
Focus
Continuity, Efficiency Independence, Focus,
Efficiency
Community Search   Reliability,
Search
ISOCNZ Transition Transition Transparency,
Freedom

 

    1. Transfer . A Registrant's ability to easily transfer names from one Registrar to another is often cited as a problem for an architecture with multiple Registrars. With a single Registrar this is not a problem.
    2. Choice . The Working Group is of the view that competition will inevitably lead to new and innovative ways to provide services to Registrants. This can only assist growth and development of the Internet. The need to be innovative in order to survive is not a driver for Domainz as Registry/Registrar and therefore no matter what its intentions may be, there is the danger that services which might be offered in a competitive model are not being developed.
    3. Privacy . Where a Registrant's information is the responsibility of the organisation that they have a contract with the Registrant has greater control over privacy and use of information and knowledge of where that information is held.
    4. Single Contract . A Shared Registry system is designed to hide the Registry from Registrants. Registrants have a business relationship with a single Registrar. (The role of Agents is ignored in all options.)
    5. Stability . The Domainz registration interface is preserved meaning that no business is required to change interfaces until such time as it feels that a change is the proper business decision.
    6. Transparency . The costs of the various components are transparent. Note that in the single Registrar option the meaningful costs are that of the combined system.
    7. Fairness . All Agents or Registrars are on an equal footing. No single organisation has an advantage over its "equals" as a result of control of the Registry.
    8. Continuity . Domainz's current business model will be able to continue with minimum disruption.
    9. Profitability . Lack of competition ensures maximum control over profitability.
    10. Independence . In a competitive Registrar market there would be no need for external governance of Domainz's actions.
    11. Focus . Without the need to balance competing requirements of the Registry and Registrar businesses Domainz would have a single, simpler focus and a better defined relationship with the rest of the industry.
    12. Efficiency . Competition should lead to efficiencies in the Registrar business. In a wider sense, there is an efficiency gain in reducing duplication of databases and the need for multiple databases to be updated.
    13. Search . With a single Registrar or Registry the user community would only need to search a single site to obtain information about a domain name. This advantage may be overtaken by new technology.
    14. Reliability . The Registry would have a narrow focus on the availability and reliability of service to the community.
    15. Transition . Leaving the Registry with Domainz, in one form or another, will reduce the effort and cost of moving to a new system.
    16. Freedom . With a simpler organisation to manage ISOCNZ will be free from managing a business enabling it to focus on a broader range of Internet issues. The boundary between policy and operations will be more clearly defined.

A number of the judgments in listing these advantages are subjective. They assume that a range of benefits will come from increased competition. Some may argue that competition already exists between Agents and between domains, e.g. .com and .co.nz. The Working Group does not accept this argument. We have received sufficient evidence to indicate that current Domainz policies limit Agents' options. We have also been told several times that many Registrants are seeking a New Zealand identity such as a name in .co.nz. Finally, it must also be recognised that the aim of competition is of itself one which is mandated by ISOCNZ objects.

The Working Group believes this analysis shows the benefits of a Shared Registry System (option 3). Most advantages reside with the SRS. For the Registrant there is the question of control over the transfer of names between Registrars. We believe this can be dealt with. For Domainz and ISOCNZ there are questions of disruption caused by a change, but we do not believe these should be overriding.

Recommendation 1 . ISOCNZ adopt the independent, Shared Registry model.

The principal advantages are seen to be:

    1. The restriction of the Registry to the minimum function should introduce competition into the Registrar market and lead to a greater range of services and options for Registrants.
    2. The retention of Domainz as a Registrar will maintain the current interface ensuring stability in the market place.
    3. ISOCNZ will, in due course, have a much simpler business to manage allowing it to focus on all of its objects.
    4. The Registry becomes an entity independent of any Registrar and will have as its sole focus the efficient operation of the Register and the DNS

Consequential Issues

Resolving the question of the overall architecture establishes a framework in which to develop a complete model. There remain a number of issues that must be addresses within the chosen framework. In the following the Working Group has tried to develop its framework by elucidating its view on a range of issues. In a number of instances specific recommendations are made.

Recommendation 2 . ISOCNZ establish an Implementation Team to separate a Registry from Domainz and establish the policy necessary to govern the new framework. The Implementation Team should be composed of at least:

  • One member of the Working Group to ensure continuity with the recommendations.
  • One member of the Technical Committee to provide technical guidance where needed and liaison with ISOCNZ over the development of any technical policy required.
  • One member of the Policy Committee to liase with ISOCNZ over the development of the policy necessary for governance.
  • One member of the ISOCNZ/Domainz Relationship Working Group to provide liaison with both ISOCNZ and Domainz.
  • One representative of the Internet industry, chosen by the industry, to provide input from the industry.
  • A project manager employed on contract to oversee the implementation of the transition.

The future of Domainz . ISOCNZ policy has always identified the monopoly aspects of the Registry as something that should be "strictly delineated" and controlled by the Society to insure that its function remains "open and uncapturable". The Registrar functions of Domainz do not qualify as a necessary monopoly. Against this is the need to maintain stability and to create an opportunity for other Registrars to enter the business.

The intent is to remove the Registry from Domainz, leaving Domainz's current interface to its Agents and Registrants intact. This will provide stability for the medium term future. ISOCNZ should retain control of Domainz until (1) the Registry has been cleanly separated; and (2) current Agents have had a sufficient opportunity to transfer their Registrants from Domainz to the Registry if they so wish. Once this has been achieved ISOCNZ may wish to review its ownership of Domainz.

It is inevitable that Domainz will inherit a considerable number of domain names within .nz. This does not greatly concern the Working Group provided the terms of the above recommendation are met. Many potential Registrars do not see domain name registration as a core part of their business and will become Registrars because of the efficiencies offered. This group will be concerned that they are not hindered in changing from being an Agent of Domainz to a Registrar. Other candidate Registrars are likely to have a well established presence in other top level domains and Domainz's head start within .nz will not be seen as a significant disadvantage.

Accreditation of Registrars . Within its model ICANN has erected substantial barriers to becoming a Registrar. Should this also be true in New Zealand? The working group identified three possible levels of specification for accrediting a Registrar.

  • Any legal entity capable of signing a contract.
  • A minimum level of "maturity" as might be represented by $500,000 in liability insurance, the absence of Directors with a criminal background and the annual presentation of a solvency certificate from an independent auditor.
  • A high level of "maturity" along the lines of ICANN's requirements.

The Working Group strongly believes that the use of subjective judgment should be avoided. Given the size of the New Zealand market and a national culture that believes in letting anyone have a go we see no reason to place unnecessary barriers in front of potential Registrars.

Recommendation 3 . Any organisation capable of undertaking a legal commitment; willing to sign the appropriate contract; and able to pay its invoices in a timely fashion should be allowed to be a Registrar.

The Charging Regime . A goal of the Working Group is to establish a Registry which provides a flexible platform allowing Registrars to offer a variety of services and does this at minimum cost. While we do not wish to overly specify the business of the Registry, we have learned how an inappropriate charging scheme can impact on Registrars. Further Domainz has indicated that it is not worth sending an invoice for less than $30.

Recommendation 4 . The charging policy of the Registry should:

  • Reflect the Registrar's use of the Register on a monthly basis being an accumulation of easily identified items such as storage, creation and deletion of records.
  • Include either a fixed or minimum monthly charge set at a level to discourage Registrars managing less than 100 names, e.g. about $100.
  • Be independent of the duration of a Registrant's license to use a name.

There is interaction between accreditation and the charging regime. The Working Group has assumed that the future cost of a domain name will be small, certainly less than $20 per annum. This can only be achieved by eliminating the invoicing of individual Registrants on an annual basis. We believe this is best achieved if the Registry invoices 50 to 100 Registrars for at least several hundred names. We do not wish to dictate who can and cannot become a Registrar. Thus the Working Group favours minimal accreditation requirements and a charging regime that discourages Registrar's with less than one hundred names.

Information in the Register . The information held in the Register has been an area of contention. ICANN absolutely minimizes this to the extent that the Registry must use the Registrar to contact the Registrant. There are two core arguments for keeping the record in the .nz Register small. Firstly, information held in the Register is almost certainly duplicated by the Registrar and possibly an Agent meaning that the consistency of multiple entries must be maintained and all changes replicated in each database. The second argument is more tenuous and seems to arise more from the current operation of Domainz. This argument minimises the information available to the Registry (through the Register) to prevent the Registry from developing a business relationship with the Registrant. RFC 1519 also requires that "There must be an administrative contact and a technical contact for each domain." However, it does not stipulate that these must be held in the Register; the implication is that the information must be readily available for on-line enquiry.

Recommendation 5 . The following information should be held in the Register for each domain name.

Domain name. Required for correct operation of the DNS.
Server ip address x 2.
Server domain name x 2.
Registrar identification and authentication. The Registrar acts on behalf of the Registrant in making changes to the record and must be identifiable.
Registrant identification and authentication. Examples of situations in which the Registry may need to authenticate or contact a Registrant include:
  • A request from a Registrant to verify the information held in the Register about their name(s).
  • A request from a Registrant to change the Registrar associated with a name.
  • The failure of a Registrar requiring the Registry to advise the Registrant of the status of their name.
Registrant technical and administrative contacts. It is proposed that these be present but may optionally indicate the Registrar. See the discussion below.


The Working Group believes that the administrative and technical contacts as specified in RFC 1519 should continue to be available. It would be desirable if this information were available from a single information service using a standard protocol and format. We know that this information is not held by all organisations that are likely to become Registrars. Therefore we conclude that the burden of providing this service falls on the Registry.

To minimise the impact of replicating data we propose that a Registrar and Registrant may agree that the Registrar be named as one or both of the administrative and technical contacts. This will allow these items to remain constant in the Registry. The Registrar will be responsible for providing the correct and current information.

Governance . An argument that has been raised in the past against a model which enforces the presence of a Registrar between the Registry and the Registrant is the possibility that a Registrar may abuse their control over a Registrant's domain name. For example, one Registrar may refuse to transfer a name to a second Registrar during a period of dispute with the Registrant holding the name.

The Working Group believes such concerns should be addressed through a clear policy statement of the rights and responsibilities of all parties with enforcement through contracts. We offer the following as a list of the rights and responsibilities of the key roles in our model.

Role Rights Responsibilities
Registrant - Listing of domain name and correct binding in DNS.
- Information maintained correctly and securely.
- Access to own information at all times.
- Instructions will be executed promptly.
- Advise Registrar of any change to information held by Registrar or Registry.
Registrar -"24 by 7" access to the Register. - Promptly forward Registrant's information and requests to the Registry.
- Accept all registrations in unmoderated domains.
Registry - To receive timely updates of all information it holds. - Provide the same quality of service to all Registrars.
- Liase regularly with the Registrar community.
-Contact a Registrant only in cases where the Registrar is failing to perform its responsibilities.

Recommendation 6 . ISOCNZ establish policy setting standards for the proper governance of the relationship between Registry, Registrar and Registrant and enforce these standards through contracts between the Registry and each Registrar.

Best Practice . The Registry will be a monopoly owned by a public, not-for-profit society. The Working Group believes the Registry should observe the objects of the Society and the principles of RFC 1591 in its operation. In particular, the Registry should be concerned with "responsibilities and service to the community." The Working Group knows of two efforts to develop a statement of best practice for ccTLD administration: the CENTR: Best Practice Guideline for ccTLD Managers and the Alternate ccTLD Best Practices Draft . (Both are available on the ICANN web site.)

Recommendation 7 . ISOCNZ adopt, possibly with modification, one of the above statements of best practice; or, if necessary, draft their own statement of best practice. This statement should be instrumental in the governance of the Registry and in the development of working relationships with Registrars.

Recommendation 8 . A standing committee be established to maintain communication between the Registry and the Registrars. The standing committee should be chaired by a member of the ISOCNZ Council and should include technical representatives from the Registry and a minimum of two different Registrars. (This committee might replace the current ISOCNZ Technical Committee.)

The Cost of Policy Development . ISOCNZ is responsible for the development and maintenance of policy governing the .nz namespace. This has included the development of local policy, such as this document, and participation in ICANN proceedings to ensure that New Zealand has a say and is not unfairly treated by any decisions that ICANN may take. To date this policy development has been funded by a management fee paid by Domainz.

It would be unfair to continue with this management fee. At the least it will need to transferred from Domainz to the Registry. The Working Group would prefer a more transparent charge made to those parties that benefit from the policy: Registrants, Registrars and the Registry. For example, explicit charges for policy development could be made on Registrants by adding a small charge to the monthly storage charge; on Registrars by a small charge added to the monthly fee; and on the Registry by a direct charge. These charges would be set annually as part of the ISOCNZ budget process making them subject to approval by the membership. The Working Group is aware that there are various tax and legal implications of such a move for the Society.

Recommendation 9 . ISOCNZ consult with its legal advisors with a view to establishing a method of funding DNS policy development that is fully transparent and subject to annual approval of the membership along the lines suggested in the previous paragraph.

Moderated Domains . Less than 1% of names within the .nz name space fall within one of the moderated domains. Consequently the Working Group does not believe that concern for the processing of names within the moderated second level domains should significantly impact the overall framework. We are not opposed to a policy that would require those responsible for moderated domains to provide a Registrar willing to provide the moderation. However, such a policy may prove unnecessary if Registrars are willing to build moderation into their systems. We believe a "wait and see" approach is appropriate with respect to moderation.

Financial . The Working Group was not charged with producing a complete business plan for any proposed framework. However, we felt that it was prudent to at least sketch the principal costs of running the Registry. The following table should be treated as a first cut.

Infrastructure
Capital ($.25M) 80,000
Housing ($2k/mos) 84,000
Communications ($3k/mos)
Maintenance ($2k/mos)
Staff
Admin (1 x $40k) 240,000
Technical (2 x $80k)
Finance (1 x $40k)
Management 100,000
Other
ISOCNZ policy development 120,000
Overheads 100,000
Total 724,000

At current levels of registration these costs equate to approximately $12 per domain name. The nature of the Registry makes it a good candidate for tendering to a larger organisation and the Working Group expects the above costs could be further reduced by following that approach.

Appendix A: Input Received by the Working Group

Auckland Forum Attendees

Chris O'Donoghue
Peter Mott, 2Day.com
Ray Lewis
Bob Gray
Len Gray

Wellington Forum Attendees

Michael Stevens, CPS Systems
Jim Higgins, Networking Edge and Domainz
Ewen McNeill
David Zanetti
Sean Liddall; Victoria University Information Technology Services
Hamish MacEwen
David Harpham

Consultations

Patrick O'Brien, Andrew Mason and Jim Higgins, Domainz
Craig Anderson and Jim Benson, IPROLINK
Karen Wynder, Xtra
Andy Linton, NetLink
Roger Hicks, Past Chair of ISOCNZ

Submissions

Jenny Shearer, Submission to the Review of the Registry/Registrar Structure for .nz
Robert Gray, Roles and Responsibilities in the DNS by Joe Abley and Peter Mott
Ewen McNeill, A Shared Registry for the .nz CCTLD
Jim Higgins, A Submission to the Registry/Registrar Model Review
Roger Hicks, Submission, Registry/Registrar Review
Lin Nah, Registry Review Submission
David Harpham, Shared Registry for *.nz
David Zanetti, SRS Working Group Submission

Document Actions