I submitted a comment to the IEDR's PDP comment thing earlier today.
In the interests of transparency here it is in its entirety.
Thank you for offering us the opportunity to submit comments on the policy development process
We are a significantly affected party with respect to any and all potential changes to IEDR policy and process and so welcome the opportunity to be able to submit comments on this.
We have invested heavily in promoting the IE namespace both domestically and internationally and any and all comments submitted are based on our deep knowledge and experience of the IEDR's current policies and modus operandi. While we may be highly critical of the IEDR we wish to go on the record as stating that we do not appreciate our criticism being characterised as "mud slinging". The overheads involved with registering and managing a large number of .ie domain names is considerable and the workload is exacerbated on an ongoing basis by the registry, its rules and its processes.
We reserve the right to submit additional comments on this process prior to the deadline.
Our main concern at present is that we have little or no confidence in the IEDR's ability to act as both technical and policy manager for the IE namespace and that this entire process is, therefore, fundamentally flawed.
A large part of the IEDR's current policies are highly subjective and are therefore open to the personal interpretations of registry staff.
While the IEDR may be willing to make fundamental changes to its modus operandi in order to effect a positive change and improve the operation of the IE namespace so that it works to the mutual benefit of both stakeholders and the registry, we do not feel that the organisation is either capable or sincere in its wishes to make this change.
We also feel that the organisation's charter and structure, and specifically its governance, needs to be either fundamentally and radically changed or that a new organisation should be given a mandate to oversee the management and development of the IE namespace.
With respect to the draft document under consideration we have several queries and comments.
"All policy changes will not require a public consultation"
Why not? And who will make the determination on whether a public consultation is needed or not, and based on which criteria? Will this be recorded somewhere?
There seems to be very little guidance contained in the document as to basic rules / operating principles for Working Groups. Maybe this information is contained somewhere else? Idem for mechanisms to be used to recruit volunteers for a WG or obtain public input. Conversely speaking the document is probably over specific when mentioning tools like SurveyMonkey by name.
How will consensus be determined? Is this unanimous consensus, rough consensus? A definition of consensus seems in order. The document mentions 'consensus is defined as general agreement of the group', does this mean that if one person disagrees there is no general agreement?
"The PAC may intervene and give recommendations at anytime if required to make the report more acceptable by the majority" - This sounds odd to me and not very constructive. A better approach might be to have a PAC liaison that could serve as a liaison between the WG / PAC and provide input / assistance as appropriate.
What is the mechanism for the PAC to approve the report? Are there different level of 'approval'? (I guess this might be in the terms of reference that are referred to in the document)
Who will prepare the details of the implementation? There does not seem to be any public comment / consultation foreseen on the implementation plan.
In terms of policies themselves. That the proposed forms would even consider using the concept of "temporary" is just plain wrong. Policies cannot be temporary. They need to be constructed in such a manner that they provide a level of predictability to all stakeholders.
I am still not convinced that this process is transparent enough.
Even if the IEDR staff present policy proposals to their board in an impartial manner there is no way to know how the board will cope with them. As the board is not representative of industry or stakeholders are they even qualified to make a decision on a policy proposal's validity? From recollection those few changes to policy that were processed in the last 10 years only came about after them being stalled for no good reason by the board on more than one occasion. And as the board's minutes are not public the reasoning behind any of this will never be known, which brings us back to the topic of the IEDR's suitabilty to manage the namespace.
It will be interesting to see how this all plays out
I'll probably be posting about this at greater length elsewhere...
The ICANN meeting in Nairobi seems to be attracting more publicity and debate than any other meeting in the last couple of years.
Because so many people are making noises about either attending OR not attending it.
I'm not attending. I'd love to be able to attend all the ICANN meetings, but I simply can't.
There are several reasons why I'm not attending and they're all inter-related.
To start with attending ICANN meetings is not cheap. Sure some people get funding from ICANN and 3rd parties to attend. I don't. In common with ANY business trip I have to weigh up the costs of attending with the benefits. The trip to the Seoul meeting, for example, was far from cheap. You have to factor in several things not least of them being the cost of flights and the hotels - and unfortunately ICANN meetings generally seem to end up being in hotels that cost about $200 / night (or more).
Security is another issue. Nairobi was meant to be the venue of the ICANN meeting a couple of years ago, but they ended up relocating it to LA. The security threats in Nairobi have been a matter of concern for quite a few people, but they weren't really at the forefront until quite recently. Having said that when I mentioned Nairobi to my mother she was not happy. Not happy at all and since she doesn't normally worry about those kind of things, I'd take her concerns very seriously. My business partner wasn't too happy about the idea either, so that's pretty much a clincher.
Fewer attendees might be seen as positive in some quarters, but if you treat an ICANN meeting as a business event then fewer attendees will have a direct and tangible impact on the chances of recouping the costs via sales etc., Since the ICANN public meetings are where a lot of the various groups interact then fewer attendees will mean that a lot less actual progress will be made on existing issues.
But let's go back to the two key points:
When you put them side by side it's pretty clear that it's not really a viable option for me to attend.
Of course there is always the option of ICANN moving its location or for various groups within ICANN to convene in a number of "hubs"
Ultimately everyone has to decide for themselves whether they should attend or not. I've decided not to, for my reasons, others have decided to go regardless. What irks me is when people try to make the entire "go - don't go" thing into a political and PR football.
If someone decides not to attend that is their call. Respect their decision.
If someone chose not to go because their wife was expecting, for example, there'd be no commentary. But choosing not to go because you or your dependants / relatives / co-workers etc., are concerned about your personal wellbeing shouldn't be an excuse for some people to get up on a soapbox and try to make out that they are somehow more superior and "better" by choosing to go.
I guess in some ways it's a reflection of the general attitude of people within the ICANN community. Mutual respect is sorely lacking in some quarters. People will pay "lip service" to it, but they just love the "politicking"
We've also been working closely with a lot of the registries to get good pricing on domains, so that we can pass on discounts to our clients where possible.
So a while back I registered a nice shiny .me domain name to push the domain offers - domainoffers.me (not very subtle, but do I need to be?)
We've been adding new discounts to it over the last while and yesterday we added yet another nice one which should be a nice pre-Christmas present for our Irish clients - .ie domains discounted yet again!
Register OR transfer an IE domain for a mere €16.95 / year - no restrictions on the number of domain years you want either and all domains come with FREE DNS.
We've also cut the price on .com registrations AND transfers down to a paltry €4.99 until the end of the year, which is a pretty aggressive price.
Now I'm off to grab more pressies for relatives and friends online ...
No day is every really as productive as I'd like it to be, but today was pretty good!
To start with I finally had a few quiet minutes to myself and was able to book my flights to Sydney for the ICANN meeting. I had tried to book it online, but I couldn't make sense of the times / dates ie. if you leave Dublin on Friday, which day would you arrive in Sydney. Solution was to just ring Trailfinders and let them worry about it. They also gave me a better rate on the ticket than I'd found online, so it was a "win win" situation. Now all I have to do is either persuade the Hilton to give me a better rate or else find a different hotel....
The other bit of progress today was that we finally launched Windows 2008 with IIS7 on our shared hosting platform. We're giving the first 100 signups for a Windows 2008 Minimus plan a massive 20 euro off, so you can get your site hosted on the latest Microsoft server platform for a mere 29.95 for the first year!! (More details here)
Now if only I could work my way through the rest of my todo list...