Provisions For Equivalent Access By Accredited Registrars


Section IV — Provisions For Equivalent Access By Accredited Registrars

  Executive Summary
C20. Instructions
C21. Proposed Methods to Provide Equivalent Access
C22. Registry Transition: Support for RRP and EPP
C23-24. Intentionally Omitted

Executive Summary

Public Interest Registry (PIR) and its subcontractor Afilias will fully comply with the proposed equivalent access requirements and deliver equal access to both its shared registry system and its registry resources to all ICANN-accredited registrars. We will implement the Registry-Registrar Agreement (RRA) currently in force with the new gTLD's (e.g. .INFO). Our key contact with registrars, Afilias, has already in place approved and working mechanisms for the provision of equivalent access to its registry services by all registrars. Afilias has an excellent record of providing equivalent access, which it expects to build on with .ORG.

The RRA will set the standards for our interactions with registrars and is based on clearly defined policies, mechanisms, and commitments that ensure equivalent access. As detailed in this section, these include: providing capacity to handle all registrars (connections, customer service); technical support via phone, e-mail and Web site that operates 24 hours each day, 7 days each week, 365 days each year; Organizational Conflict of Interest (OCI) training of all relevant staff; annual certifications and sign-off by staff; regular internal neutrality reviews; a clear Registry Code of Conduct and mechanisms for guaranteeing the confidential treatment of registry and registrar information.

Our "24x7x365" service policy will address the needs of registrars in every time zone. From a language standpoint, we propose for now to maintain English as official language for providing registry services in .ORG. We would add languages in the future as the marketplace dictates.

PIR is committed to providing a smooth transition to new version of the EPP protocol once it is published as an IETF Standards Track RFC. Our transition plan (detailed in Section III) includes tools and transition help for registrars moving to EPP (OT&E assistance will be available to all). The plan also supports RRP through a proxy for those yet to complete the conversion. Net, all current .ORG registrars will have uninterrupted support during the transition.

Beyond this, PIR is committed to promptly adopting the new EPP standard when it is approved and published as an IETF Standards Track RFC. Through ISOC, PIR will be closely following the standards process to ensure it is prepared to quickly transition .ORG registrars to new standard once approved.

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C20.  Instructions

The selected successor operator for the .org registry will be required to provide all ICANN-accredited registrars having registry-registrar agreements in effect with equivalent access to registry services through a shared registry system, under which those registrars will provide services (either directly or through resellers) to registrants. This section of the .org Proposal covers the applicant's proposed arrangements for interacting with registrars in a manner that provides equivalent access.

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C21.  Proposed Methods to Provide Equivalent Access

Describe in detail your proposed methods of providing registry services on an equivalent basis to all accredited registrars having registry-registrar agreements in effect. Your description should include any measures intended to make registration, technical assistance, and other services available to ICANN-accredited registrars in different time zones and relevant languages. In addition, describe the Registry Code of Conduct and other commitments you propose to make to ensure that all such registrars receive equivalent access to registry services.

  1. Public Interest Registry (hereafter called PIR), and its subcontractor, Afilias, intend to provide all ICANN-Accredited registrars who have executed a Registry-Registrar Agreement with equivalent access to its Shared Registry System (SRS). Upon execution of the .ORG Registry Agreement, the registry will have each registrar with a Registry-Registrar Agreement in effect with VeriSign execute a PIR Registry-Registrar Agreement, similar to Appendix D. We have modeled Appendix D from Appendix F of the .INFO Registry-Registrar Agreement. (We acknowledge ICANN's permission to use its copyrighted materials in this fashion.)

  2. PIR will provide registrars with equivalent access to the SRS via the Extensible Provisioning Protocol (EPP) once the transition from the Registry-Registrar Protocol (RRP) to EPP is complete. During the transition period, registrars who wish to use RRP will be provided equivalent access to the SRS through an RRP-to-EPP Proxy until the registrar has passed the EPP Operational Test and Evaluation certification process.

  3. The transition time should be short, based on our research of .ORG registrars. Presently, more than 99% of currently registered .ORG domain names are with registrars who are currently accredited by our subcontractor, Afilias, and are utilizing EPP.

  4. Registrars will receive assistance with the transition from RRP to EPP through Afilias Technical Support, which operates 24 hours each day, 7 days each week, 365 days each year (24x7x365). Technical Support presently provides assistance to registrars via telephone, e-mail, and the registry Web site.

  5. All ICANN-accredited registrars will have the same access to customer support, administrative, and business services.

  6. All ICANN-accredited registrars will have the same access to the tools required to access their data through the Registry System including billing, account management, and other similar services.

  7. With the exception of systems designed to enforce PIR's or ICANN's terms of service, contract, or policy, the Registry System does not include any features or systems designed to perform prejudicially or favorably towards any specific ICANN-accredited registrar or registrars.

  8. To ensure that all ICANN-accredited registrars receive equal treatment from the registry, PIR will make a certification to ICANN in a format similar to the Equivalent Access Certification identified as Appendix E. Such certification will be provided semi-annually and state that PIR, in its capacity as Registry Operator, and on behalf of its contractors, is providing all ICANN-accredited registrars with equivalent access.

  9. Afilias, the provider of technical registry services for PIR, has represented to PIR that it will comply with the Equal Access and Nondiscrimination Practice Plan, that is presently included in the ICANN/Registry Agreements for .COM, .NET and .INFO (the "Plan"). PIR will ensure that its subcontractor, Afilias, complies with the Plan and in the event that Afilias is terminated or replaced as the provider of technical registry services to PIR, will ensure continued compliance with the Plan.

  10. PIR and Afilias will have various procedural safeguards in place to ensure that the data and information of the registry business are not utilized to the advantage of one ICANN-accredited registrar over another or others.

  11. All PIR personnel and contractor employees who have a need to know PIR business will undergo a formal Organizational Conflict of Interest (OCI) Training Program that will provide a clear understanding of the Plan and will focus on the Equivalent Access Policy and their responsibility under the Plan. All staff members will be required to receive OCI training before they are given an assignment or access to PIR and Afilias material. Annual OCI refresher training will be required.

  12. PIR and Afilias personnel will be required to sign a nondisclosure agreement and a PIR Business Organizational Conflict of Interest Avoidance Certificate similar to the documents identified as Appendix F and G, respectively. The employees will be certifying that they have an understanding of the OCI requirements and that they will strictly comply with the provisions of the OCI Plan. These documents will be maintained in the individuals' personnel files.

  13. The Presidents and or CEOs of PIR and Afilias will, in all cases, endeavor to ensure that Afilias and its employees do not release any information to any ICANN-accredited registrar, or their respective employees, that could be used by an ICANN-accredited registrar to the detriment of any other ICANN-accredited registrar regardless of the official stated sensitivity of the information. Under no circumstances will registry sensitive information be approved by the Presidents/CEOs for release to any other ICANN-accredited registrar.

  14. While Afilias is owned by a consortium of 18 registrars, (and all are .ORG-authorized already), ALL of these 18 registrars have signed a shareholder agreement that already ensures that NONE of these owners may obtain any information from Afilias that could be used as a competitive advantage of any sort. This arrangement has been in place for more than a year regarding Afilias' .INFO registry operations, and we are confident a similarly successful implementation will occur for .ORG.

  15. PIR and its subcontractor propose to establish data access policies for the protection of proprietary information that might be developed by PIR and its contractors. Proprietary or confidential information could be of financial, personnel, technical, or business nature. It will include computer software, software documentation, computer programs, and software databases.

  16. PIR and its subcontractor, Afilias, propose to protect any Registry Sensitive Information to ensure that the revenue and assets of PIR are not unfairly utilized to advantage another ICANN-accredited registrar to the detriment of other competing ICANN-accredited registrars. This policy will be applicable within PIR and Afilias and applicable to all officers, employees, members, directors, shareholders, agents or subcontractors of PIR and Afilias.

  17. PIR will conduct internal neutrality reviews on a regular basis. In addition, PIR and ICANN may mutually agree on an independent party to conduct a neutrality review of PIR, ensuring that PIR complies with all the provisions of this Registry Operator Code of Conduct (see Appendix I). The results of the review will be provided to ICANN and shall be deemed to be confidential and proprietary information of PIR.

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C22.  Registry Transition: Support For RRP and EPP

VeriSign, Inc., the current operator of the .ORG registry, uses a registry-registrar protocol (RRP) documented in RFC 2832. At the time of the transition, the selected successor operator will be required to continue to support the RRP (unless a migration of registrars in .ORG to another protocol has already been completed by that time). In addition, the selected successor operator will be required to implement support for the IETF provreg working group's protocol specification for an Extensible Provisioning Protocol (EPP) no later than 135 days after it is adopted as a Proposed Standard [RFC 2026], section 4.1.1]. Provide a detailed description of your plan for supporting RRP at the time of transition, for supporting EPP within the required time frame, and for providing registrars with a smooth, low-cost migration path from RRP to EPP.

  1. PIR chose to partner with Afilias as a registry infrastructure provider based upon its experience as the first registry operator to successfully build and deploy a registry system using the EPP protocol. In fact, more than one hundred ICANN-accredited registrars are using Afilias' EPP system on a daily basis to connect to the .INFO registry, which has more than 800,000 domain names under management.

  2. However, we understand the necessity for supporting RRP throughout this transition period, and have designed a process that will allow registrars to continue to use RRP through the transition, and cut over to EPP when they are ready. This will help make the .ORG transition as painless as possible for the registrars as they move to a new registry operator.

  3. The new .ORG registry will be modeled from the ground up using EPP. Registrars who are comfortable using EPP may choose to do so on the very first day of operation. Additionally, we will have an RPP to EPP proxy system in place that registrars using RRP can use until that time when they are ready to cutover to EPP (as stated in Section III). This system will include central WHOIS services from initiation. For initial RRP.ORG names, the WHOIS service will provide a referral to the authoritative WHOIS servers. Part of the RRP to EPP migration will incorporate populating required contact information to permit thick registry WHOIS services - thus EPP migrated .ORG names will return authoritative WHOIS information. Our systems currently utilize various levels of the pre-standard EPP protocol, including the latest pre-standard version. PIR fully expects to implement the standards well within the 135 days after they are adopted.

  4. Once the .ORG bid has been awarded, PIR will put both an RRP and an EPP test area ("sandbox") in place for all registrars to begin testing their client code. Each registrar will be required to pass an Operation Test and Evaluation (OT&E) before using either protocol. The certification process will be easier for those registrars currently accessing the Afilias SRS using the EPP protocol. PIR staff, to ensure registrars get sufficient help during the test and pass in a reasonable timeframe, will carefully monitor this test.

  5. All registrars that pass the EPP OT&E certification before registry operation begins will be allowed to begin operations using the EPP protocol. Those that are not ready must pass the RRP OT&E before the go live date, and PIR will provide as much assistance as is commercially feasible to help each registrar complete one of these certifications.

  6. The registry will be pre-loaded with all relevant RRP data from VeriSign (See Section III, C18). If a registrar connects to the registry using RRP, it will be able to manipulate the data in the same manner as today through VeriSign. If the registrar connects via EPP, it will need to modify the domain name to include all required fields for that entity and its children (contact ROIDS, etc.). This modification step will be included in the OT&E process, assuring that registrars know exactly what to do. This will effectively convert the record "on the fly", again making the transition easy for registrars.

  7. The registry will encourage registrars to migrate their data from the thin to thick registry model. This encouragement will include, but is not limited to, a weekly report showing all domains still under the thin model, possible incentives to migrate the data, full technical support and OT&E testing facilities, and notifications by the registry to migrate the data in a timely fashion.

  8. After the registry has come on line, each RRP registrar will be contacted by PIR to schedule that registrar's cutover to the new version of the EPP protocol once it is published as an IETF Standards Track RFC. PIR and Afilias may provide assistance in integrating and developing software for each registrar to move to EPP (See Section V). This will lessen the resource burden on each registrar to make the move to EPP and help ensure each transition is smooth.

  9. Once all registrars have made the transition to EPP, the RRP-to-EPP proxy will be shut down, and all registry operations from that point forward will be transacted using EPP.

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C23–24.  Intentionally Omitted

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