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.
Operating as a trustee of numerous mission-critical resources, NeuStar has a legacy of providing neutral, even-handed services in highly competitive environments to ensure that resources are managed to serve community interests. NeuStar ensure equal access and fair treatment through several important mechanisms:
In addition, as a technical services company, NeuStar must also ensure that its technical operations promote equal access. For the needs of the .org registry, NeuStar has developed a plan for the migration of the .org registrars from the proprietary RRP protocol to the open EPP protocol in a manner that ensures equal access by registrars during each step in the process.
|C21.||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. In preparing
your response to this item, you may wish to refer to Appendices H and I
of the registry agreements ICANN has entered for unsponsored TLDs (e.g.,
Leveraging its legacy of successfully providing even-handed services to all, NeuStar will implement and operate the .org registry under a strict code of conduct and principles of fair-treatment that will enable competition among all ICANN-accredited registrars.
Fairness is central to the role of the .org registry operator. As the trustee of an important public global resource, ICANN is required by its Articles of Incorporation to promote the public interest in a neutral manner. Consequently, ICANN operates for the benefit of the Internet community as a whole, carrying out its activities in ways that enables fair competition and open entry into Internet-related markets. Similarly, the .org registry operator must demonstrate that it can treat registrars equally and fairly in providing access to registry services.
Registrars with NeuStar’s current registries already enjoy equivalent and fair access to registry services. NeuStar accomplishes this by committing to the following:
For the .org registry, NeuStar proposes to maintain these established mechanisms for providing registry services to registrars on an equivalent basis.
Code of conduct
.org TLD code of conduct
Avoiding conflicts of interest. As required by Section 3.5.3 of the draft registry agreement for the .org TLD, NeuStar will not serve as an accredited registrar of .org domain names while serving as the registry operator under the .org TLD. Moreover, NeuStar can make the further representation that it is not owned or controlled by any prospective .org TLD registrar.
As ICANN is no doubt aware, the combination of a registry operator and its registrars, whether in function or by ownership, invariably leads to conflicts of interest inconsistent with both ICANN’s mandate to promote the public interest in a neutral manner and the registry operator’s requirement to provide registry services to all accredited registrars on an equivalent basis. For example, a registry operator that is owned or otherwise controlled by registrars for the same TLD is subject to immense pressure to make decisions benefiting the limited number of registrars who happen to own or control the registry operator at the expense of the Internet as a whole and other ICANN-accredited registrants in particular. Furthermore, and for the same reasons, such a registry operator likely will lack the independence necessary to enforce ICANN policies and the requirements set forth in the registry-registrar agreement.
NeuStar will not place itself in a position where a conflict of interest might compromise its neutrality. Furthermore, NeuStar agrees to abide by its Code of Conduct (see above), which prohibits NeuStar from:
NeuStar takes its neutrality obligations seriously. For the operation of the .org TLD registry, NeuStar will continue avoiding any conflicts of interest that detract from ICANN’s mission to promote the public interest in a neutral manner.
Statement on equal access and non-discriminatory practices. As part of Exhibit H of the registry agreement, the NeuStar Statement on Equal Access and Non-discriminatory Practices (the “Statement”) details NeuStar’s internal mechanisms for ensuring that registrars of the .org TLD are treated fairly by the registry operator. With respect to the Statement, NeuStar proposes to accomplish the following:
As with its .biz TLD operations, NeuStar proposes to implement the Statement by taking the following affirmative steps:
NeuStar has successfully employed the Statement and implemented the foregoing measures in its current TLD registry operations. For the .org TLD, NeuStar proposes to continue meeting these well-developed requirements.
Unlike other companies capable of operating a domain name registry, NeuStar has been subject to and has successfully operated in accordance with numerous neutrality regimes, including those that apply to the following NeuStar operations, which are further described below:
gTLD registry—Under Section 3.5 of its agreement with ICANN for the operation of the .biz registry, NeuStar is required to provide all ICANN-accredited registrars with registry-registrar agreements equivalent access to registry services, including to its shared registration system. Moreover, the same agreement requires that NeuStar ensure that its revenues and assets are not utilized to advantage affiliated registrars to the detriment of other ICANN-accredited registrars.
ccTLD registry—Under its agreement with the United States Department of Commerce, NeuStar serves as the accrediting body for registrars seeking to register domain names under the .us ccTLD. Under that agreement, NeuStar is obligated to provide a “fair” accreditation process and “ensure neutrality of the registry”.
Numbering and portability—As part of its approval of NeuStar as the North American Numbering Plan Administrator (NANPA), the United States Federal Communications Commission (FCC) requires that NeuStar ensure certain protections to safeguard its neutrality. These safeguards include:
Even though the FCC declared in December 1999 that NeuStar met these neutrality requirements, NeuStar continually ensures it adherence with these regulations as it grows existing businesses and offers new services.
Further, NeuStar’s contract with the North American Portability Management (NAPM) for Local Number Portability Administration (LNPA) call for similarly stringent adherence to neutrality requirements.
NeuStar believes that it is uniquely qualified to ensure the success of the .org TLD. Our plan builds on NeuStar’s legacy of managing public resources in a responsible and neutral manner. NeuStar’s proven experience in operating under various neutrality requirements will deliver a high level of service to the noncommercial community.
Registration, technical assistance, and
NeuStar proposes to continue providing these high-quality services to registrars under the .org TLD, thus ensuring that registrars are granted an equivalent level of support regardless of the time of day or where they are located. For more information on the support services, please see Section C17.11 of NeuStar’s Proposal for the Reassignment of the .org TLD.
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.
NeuStar is dedicated to the development and implementation of open industry standards. Common, well-documented interface protocols are critical to the overall stability of the Internet. More importantly for .org, it is critical to ensure the stability and integrity of the registry, as well as for providing equal and fair access to each of the .org registrars. Proper management of the registry-registrar interface through the transition and ongoing operations will be a crucial element in ensuring the stability of the namespace.
Currently, the registry interface for .org uses a protocol called the Registry Registrar Protocol (RRP), documented in IETF Informational RFC 2832. RRP is a proprietary protocol developed by the incumbent registry. Thus it has not gone through the process of peer review required of an industry standard. The domain industry has recently begun an evolution of the registry-registrar model from proprietary protocols, like RRP, to the open Extensible Provisioning Protocol (EPP). EPP is in the process of becoming an IETF standard. NeuStar fully supports the EPP protocol and has been a primary participant in its development. Therefore, the successor registry for .org must account for the fact that the .org registry currently utilizes the RRP interface. The new .org operator will need to develop a comprehensive plan for the easy, low-cost migration of the .org registrars to the EPP protocol once it is recognized as a proposed standard by the IETF.
A successful migration from RRP to EPP must address three primary concerns in order to properly serve the .org community. These are:
NeuStar’s solution addresses these concerns:
The following discussions provide more detailed discussion of each element of the NeuStar protocol migration solution.
Support for RRP
NeuStar strongly advises that only the third option will ensure that the migration meets the requirements listed above. Requiring migration to EPP at the time of transition raises the concern that not all registrars would have the resources to make the migration in time to participate in the transition. This approach would result either in some registrars lacking equal access, or delay of the transition. In addition, a basic principle of transitioning critical infrastructure is that you must minimize the number of variables in the process. Requiring movement to EPP at the same time as the transition introduces additional variables and thus additional risk. Therefore, this first option is unsatisfactory.
The second approach would be for the new registry to offer both an EPP and RRP interface at transition. The registry provider would then evolve all registrars to the standard EPP interface after it has been designated a standard by the IETF. While at first glance, this approach may seem attractive, it actually would create the possibility for different levels of access for different registrars. A common interface ensures that all registrars are treated the same because all registrars have access to the same interface documentation and the registry processes all commands in the same manner. Also, multiple interfaces create the possibility for corruption of the .org database, and for causing problems with registrar transfers. For example, questions could arise regarding whether a name is registered, to whom it is registered, and the actual expiration date for a given name. Obviously, the .org community would not be well served if the data within the .org database could not be trusted. Thus, this approach also would endanger the success of the transition.
Given the potential harm from these approaches, NeuStar proposes that the most reasonable and responsible approach is to migrate from RRP to EPP only after the successful transition of the registry. NeuStar will update it's current registry to provide an RRP interface to .org. The NeuStar .org registry will be compatible with the current toolkits provided by VeriSign and used by the current .org registrars. There will be a test environment and technical support provided to the registrars for system testing prior to the transition. NeuStar will work with the registrars to test and implement their interface to the new registry. Then we will work with the registrars to transition the registry from VeriSign to NeuStar using a common RRP interface.
Once the registry is transitioned using the common RRP protocol, NeuStar would have the opportunity to analyze the stability of the registry, as well as the registrar operations and interface. After determining that the transition has been completed in a stable manner, it would be safe to begin a migration to EPP, while working closely with registrars to address any significant issues.
The benefits to the .org community of NeuStar’s approach are significant. The primary benefit is that it eliminates risk of data corruption or stability problems as a result of conflicts between the protocols. Also, it ensures that the registrars, at all times, are treated equally. Finally, because RRP is currently used by the registrar, this approach represents the easiest and lowest cost approach during the transition. Following transition, NeuStar would provide additional tools and assistance to ease the migration and reduce impact on all registrars.
NeuStar recognizes, of course, that, in the event that all .org registrars migrate to EPP prior to award of .org to a successor operator, that operator will be required to implement dual protocols. NeuStar is prepared and sufficiently experienced to address such eventualities and work to minimize the impact of the issues discussed above if necessary. However, we strongly submit that the third approach, and NeuStar’s solution, discussed above best serves the .org community.
The migration to EPP
The registry must very closely manage the migration to a new registry interface. Change management is one of the more critical, but often overlooked, functions of any service organization, including Internet registries. Since the registry is critical infrastructure for all registries, a change to the interface dramatically affects all registrars. Further, changes to the interface can also affect changes in the .org database itself, causing potentially serious integrity concerns. For these reasons, the registry must start with a stable baseline and provide detailed oversight for each change to the interface. In some cases the changes will be minor and relatively easy to implement. In other cases, such as a change from the RRP protocol to the EPP protocol, the changes will be significant and require significant preparation, testing, and documentation.
To effectively address the many potential issues related to a protocol migration, the successor registry must have an intimate understanding of the protocols involved and the risks associated with moving from one to the other. NeuStar is an active supporter of EPP both in our registry and at the IETF. NeuStar has authored two drafts of the EPP protocol in the Provreg Working Group, the IETF Working Group responsible for EPP, and has participated in the crafting of all of the drafts produced in the working group. Moreover, NeuStar’s registry has a fully compliant EPP-04 interface. Most other registries support earlier versions of the EPP draft standard or have implemented interfaces that are not fully compliant with EPP-04.
Thus, NeuStar is uniquely positioned to transition registrars seamlessly from RRP to EPP in a straightforward and cost effective manner. We can easily transition the .org interface 135 days after EPP is made a standard, as required by ICANN. Indeed, this transition would require only minor modifications to NeuStar's current registry software and registrar toolkit.
Migration of the registry system is, of course, only half the battle. The successor registry must work closely with ICANN and the .org registrars with regard to planning and timing of the registrar migration as a number of technical protocol decisions are required. For example, RRP only supports a “thin” registry model, and while EPP can support a “thin” registry model, it is predominantly associated with a “thick” registry model. The industry and the noncommercial community should consider whether a thick or thin registry model is preferred. If a thick model is preferable, then the registry will be required to work with the registrars to determine an effective approach for updating the registry database with the EPP fields associated with the thick model. This update process will raise the costs of the transition for existing registrars and, therefore, should not simply be imposed by the registry. Similarly, if the thin model is preferable, then certain modifications will be necessary to the EPP protocol to remove the thick registry fields for the .org EPP. Currently there are no known implementations of EPP that utilize the "thin" registry options. Therefore it would be an unproven protocol.
In addition, there is a critical difference between the business rules required in EPP and those supported in RRP. EPP requires authenticating information (authinfo) to be associated with each domain name. This authinfo is required when performing a registrar transfer. If the registrar does not submit the authinfo with the transfer request the request will be denied. RRP does not provide for such a capability. This means that none of the names in the .org database have authinfo currently associated with them, nor does the registry require it when performing a transfer. A transition from RRP to EPP will have to account for this difference. Either the standard will have to be changed to delete the authinfo or the authinfo will have to be provisioned in the .org database for all existing names. The best approach to this issue will have to be considered by all affected parties.
Therefore, it is clear that there are important issues associated with the migration from RRP to EPP that must be considered by the industry. The migration must occur in a careful fashion following the registry transition. NeuStar would begin working with the .org registries on these issues immediately following transition to ensure a timely migration. Only through careful planning by a successor registry, like NeuStar, with detailed knowledge of both the RRP and EPP protocols, will the .org registrars experience a seamless migration from RRP to EPP.
Exhibit C22-1 provides an overview of the registry protocol migration process.
|C23 and C24. Intentionally omitted.|