[council] Statement of the NCDNHC

["Milton Mueller" <mueller@syr.edu>]

NonCommercial Domain Name Holders Constituency 
STATEMENT ON VERISIGN AGREEMENT

1. The Noncommercial Domain Name Holders Constituency (NCDNHC) has numerous concerns about the revised ICANN - Verisign registry contract posted 1 March 2001.  The NCDNHC concerns arise for both substantive and procedural reasons. However, we note that the proposed contract has some merit, and we propose changes that would allow the NCDNHC to support the
contract.

Procedure
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2. Even though the contract contains significant new policies in registrar competition and .org registration, the DNSO was not consulted. To approve
an agreement arrived at in this manner would undermine if not destroy the DNSO's policy authority, which is based on bottom-up consultation.

Substantive Issues
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3. The integration of registry and registrar functions in the dominant COM domain may be anti-competitive without other changes (see #4 and #6 below). 

4. The pace of divestiture is too slow.  The divestiture of registry operations of ORG (31 December 2002) and NET (1 January 2006) should occur
more quickly.

5. The possibility of restricting ORG to only non-profit registrants is inconsistent with long-standing policies and practices.

6. Some of the presumed benefits of the revised agreement could be achieved by rapid authorization of new top-level domains and new registries.

Positive Aspects
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7. The separation of the .com, .net, and .org registries is a positive development. The NCDNHC supports divestiture of NET and ORG from the COM
registry to promote registry competition.

PROPOSED CHANGES
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8. Accelerate the divestiture of ORG and NET to 1 November 2002.

9. As a supplement to the contract revisions, we support the creation of new gTLDs devoted to unrestrcted use and non-profit organizations by June
2002.

10. Ensure that the ORG domain remains open to miscellaneous use and that the renewal rights of existing holders of ORG domains are not affected in
any way by the transfer of administration.