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Letter from Cord Wischhoefer (ISO 3166/MA) to Louis Touton and Dr. Paul Twomey
(30 August 2001)
Posted: 5 September 2001



From: CORD WISCHHOEFER
Sent: Thursday, August 30, 2001 8:10 AM
To: root-mgmt@iana.org; Paul.Twomey@noie.gov.au
Cc: rene.azoulai@sita.int; Rosa.Delgado@sita.int; gosta.roos@ties.itu.ch
Subject: Second Level Domains in the .aero TLD


Dear Mr Touton,
Dear Mr Twomey,

On 17 July 2001 the ISO 3166 Maintenance Agency Secretariat (ISO 3166/MAS) received a request concerning the reservation of two-character label strings in the second level domain of the .aero Sponsored Top Level Domain (sTLD), following the procedures included in Annex 13 [sic, Attachment 11] of the Proposed TLD Sponsorship Agreements for new generic Top level Domains (Annex I).

We contact you as the heads of the IANA root management and the ICANN Government Advisory Committtee, respectively, to state our opinion on this request.

It has been the policy of the ISO 3166/MA to advocate against using two-letter combinations (or even three-letter combinations) as Second Level Domain identifiers in order to avoid ambiguity that might arise if users of the DNS mistook these two-letter combinations for ISO 3166 alpha-2 codes, i.e. ccTLDs.

Now SITA, the Sponsor of the new sTLD (".aero"), informed us about their intention to use IATA 2-character airline designator codes (Resolution 762) in the second level domain of the structure of the new .aero TLD.

We discussed this request with Ms Rosa Delgado, Internet Industry Relations Director of SITA. Relevant excerpts of these discussion via e-mail are attached to this document. (Annex II)

Ms Delgado informed us that SITA is working in close collaboration with the main aviation organizations i.e. IATA (International Air Transport Association), ICAO (International Civil Aviation Organization), ACI (Airports Council International) and SITA (Société Internationale de Télécommunications Aéronautique) in this area.

As .aero is a restricted TLD specifically addressed to the global aviation community, SITA believes that the utilization of the IATA two-character airline codes provides a real value to specific communities and enhances the utility of the sTLDs in cyberspace.

After having considering all information provided by SITA we would like to state the following:

The ISO 3166/MAS does not object to the request of SITA. We do not expect any serious problems if SITA reserves the IATA two-character airline designator codes in the restricted .aero domain. However, we request that SITA states clearly and publicly that two-letter combinations preceding .aero have nothing to do with the ISO 3166-1 two-letter codes (i.e. ccTLDs) in the .aero TLD.

The reasoning for this attitude of the ISO 3166/MAS is as follows:

IATA two-letter codes for airlines have been in use in the aviation community for about 50 years. They are a well established coding system within that community. The chances that these two-letter code elements can be mistaken for ISO 3166-1 Alpha-2 code elements are thus quite small.

Finally, we would like to state that the assessment of the particular situation within the aviation community (.aero) made by the ISO 3166 Maintenance Agency Secretariat must under no circumstances be regarded as setting a precedent for possible uses of two-letter codes as SLDs in other new TLDs.

If you have any questions on this issue please don't hesitate to contact us.

Best regards

Cord Wischhöfer
for the Secretariat of the
ISO 3166 Maintenance Agency
Tel.: +49 (30) 26 01 28 61
Fax: +49 (30) 26 01 12 31
E-Mail: cord.wischhoefer@din.de
URL: www.din.de/gremien/nas/nabd/iso3166ma/


cc:
Ms Rosa Delgado, Internet Industry Relations Director of SITA
Mr Rene Azoulai, Executive Vice President Network Services & Corporate of SITA
Mr Gösta Roos, Chairman ISO 3166/MA


Annex I: Except from Proposed TLD Agreement

The Proposed TLD Agreement: Appendix 13: Reserved Names (New TLDs Proposed TLD Sponsorship Agreements with ICANN) http://www.icann.org/tlds/agreements/unsponsored/registry-agmt-appk-26apr01.htm

B. Additional Second-Level Reservations. In addition, the following names shall be reserved at the second level:

  • All single-character labels.
  • All two-character labels shall be initially reserved. The reservation of a two-character label string shall be released to the extent that the Registry Operator reaches agreement with the government and country-code manager, or the ISO 3166 maintenance agency, whichever appropriate.The Registry Operator may also propose release of these reservations based

Annex II: Email-discussion between SITA and ISO 3166/MAS

From: Rosa Delgado on 01.08.2001 12:54
To: "Cord Wischhoefer"
cc: <Rosa.Delgado@Sita.Int>, <Clivio@Iso.Ch>, <Gosta.Roos@Ties.Itu.Ch>
Subject: Re: aero TLD and Country codes ccTLDs

Dear Mr. WISCHHOEFER and Roos,

Many thanks for your message. Please see my responses below.

I hope we can extend your views to ICANN. We require a text which states ISO's position which should be sent to ICANN and GAC for their consideration, as you clearly mentioned below.

The next ICANN meeting is to be held 7-10 September in Montevideo and we would like to discuss this issue in more detail with them.

We appreciate the time you have given to our request

Many regards

Rosa Delgado
Internet Industry Relations Director
SITA
Tel: +41.22.747.62.66

"CORD WISCHHOEFER" on 25.07.2001 10:27:51
To: <Rosa.Delgado@Sita.Int>
cc: <Clivio@Iso.Ch>, <Gosta.Roos@Ties.Itu.Ch>
Subject: aero TLD and Country codes ccTLDs

Dear Ms Delgado,

Your e-mail to Mr Roos, chairman of the ISO 3166/MA, was forwarded to him. He is at present not in Geneva so it is likely that he won't be available for a meeting (as you proposed).

I talked about the issue of the airline-code SLDs in the aero-TLD with the Mr Roos on the telephone yesterday.

We have a few questions.

1. Why don't you use the three-letter airline code which IATA adopted about ten years ago and which is to replace the two-letter code? E.g. Scandinavian Airlines is SAS in that code and SK in the two-letter code. You would not even have a remote possibility of mistaking these three-letter codes for ccTLDs.

RD>> The reasons are:

- IATA's two-character airline identifiers are the most common identifiers used by the airlines. Three-characters code are less used. Most airlines only have the IATA two-characters code. IATA predicts that only in about 5 years from now the 3-character code will be used by all airlines.

- IATA's three-character location (airports) designators represent locations (airports), therefore as such will be registered in the .aero TLD representing airports

2. If using the IATA three-letter code for airlines is not possible (e.g. because the three-letter airport codes could be mistaken for airline codes) then there is the problem of regional duplication. As far as we know the two-letter code for airlines is exhausted, i.e. all code elements are used and none are left for assignment. In order to get around this problem IATA assigns identical code elements to different airlines provided they don't serve identical destinations. So a regional airline in Africa and one in Asia can have the same IATA two-letter code element. How do you solve this problem of duplication if you use the IATA two-letter code in the world wide web (which is not regional at all)?

RD>> Yes, you are correct. In order to overcome this problem SITA in co-ordination with IATA have resolved to differentiate the two identifier holders by adding xx-(airline category) to the second option.

for example:

china xinjiang airlines: XO
second airline ... XO-M

Now, as far as the ISO 3166/MA and ISO 3166-1 is concerned we do not foresee any major problems if SITA uses the IATA two-letter codes as SLDs in the .aero domain. The worry that these codes could be mistaken as relating to country names needs to be taken seriously, however. A user of the Internet who knows a little about the structure of the DNS will know that a ccTLD is a combination of two letters as the terminal part of an Internet address. This ccTLD is never followed by a dot. So "ba.aero" or "sk.aero" cannot be mistaken as a relating to a ccTLD by an experienced user of the Internet.

RD>> We would like to ensure that no confusion would be added if the .aero TLDuses the 2-characater airline identifiers in the SLD. Sponsored TLDs represent specific sectors of the community and with such a precedent of using aviation international codes, in the case of .aero makes these TLDs more representative of corresponding communities. We feel that it is a valid requirement of the aviation community.

If SITA states clearly and publicly that possible two-letter combinations preceding .aero have nothing to do with the ISO 3166-1 two-letter codes (i.e. ccTLDs) then we would not object against SITA using such two-letter combinations as SLDs. However, we do not administrate the DNS. If ICANN and/or the ICANN-GAC object against such SLDs in the .aero TLD then their concerns should be taken very seriously and another solution should be found.

RD>> SITA will state clearly and publicly that the 2-character airline designators in the SLD of the .aero TLD do not represent countries.

Please let me know your views on the questions raised.

I am very much looking forward to your reply.

Best regards

Cord Wischhöfer
for the Secretariat of the
ISO 3166 Maintenance Agency
Tel.: +49 (30) 26 01 28 61
Fax: +49 (30) 26 01 12 31
E-Mail: cord.wischhoefer@din.de
URL: www.din.de/gremien/nas/nabd/iso3166ma/

>>> <Rosa.Delgado@sita.int> 17-07-01 13:42:56 >>>

Dear Mr. WISCHHOEFER,

As we discussed on the phone, I would like to explain in more detail the use of IATA 2-letter airline designators (Recommended practices 762) in the structure of the new .aero TLD. At the last ICANN meeting in Stockholm ICANN (Mr. Louis Tuton) and the GAC advised SITA to contact ISO and discuss the intention of the .aero TLD to use 2-characters airline designators in the second level domain (See reference in Annex I)

As SITA is based in Geneva I contacted the ISO Geneva office. Sophie and I have been trying to communicate with each other without success and finally we managed to talk and I am glad. Thanks to Sophie for sending me your address.

I would like to summarize our phone conversation as follows. In principle you agreed with the fact that:

- the use of IATA 2-letter airline designators (Recommended practices 762) in the second level domain of the .aero TLD is not in conflict with country codes - ccTLDs- ISO 3166 addresses.

- IATA codes in the SLD of the .aero TLD represent airlines designators and not ISO 3166 country codes.

Finally, I proposed to you that both (ISO and SITA) could draft a text which will be addressed to ICANN (Louis Tuton) and the governmental representatives on the GAC with the purpose of requesting an exception for the .aero TLD in this endeavour.

I would be grateful if you could let me know how to proceed and to be able to formalize a text that will ensure that the .aero TLD will be able to accommodate aviation codes in its structure that have been in use by the entire aviation community for the last 50 years.

Best regards

Rosa M. Delgado
Internet Industry Relations Director
SITA

telf: + 41.22.747.62.66
fax: +41.22.747.62.01

Annex I:

1. The .aero Top-Level Domain (TLD) for the Aviation Community: .aero TLD was awarded to SITA SC by ICANN on 16 November 2000, to implement registration services for the entire Aviation Community. The .aero TLD is a restricted TLD and is reserved for the Aviation Community only. SITA and Aviation related organizations are developing a naming convention that will include names such as e.g. af.aero, ba.aero, sita.aero, iberia.aero,
boeing.aero, heathrow-aeroport.aero, duty-free.aero, and so on.

.aero will enable the Aviation Community to ensure an efficient name registration process that will meet community requirements in terms of speed, security, accuracy and reliability. The .aero TLD will allow the creation of directory services that can rapidly identify any entity, system and subsystems. It will enable the collective management of the Internet address space to eliminate any addressing obstacle in the growth of e-business applications for the air transport industry. It will also help the adoption of third-generation Internet mobile, e-business and certification services to develop new business lines.

SITA is the sponsoring organisation. SITA INC has been selected as the registry operator to offer registration services through registrars to registrants (or applicants) in the .aero TLD.

SITA established a dot-Aero Council (DAC) which will formulate policies and technical solutions concerning the operation of the service to resolve who can apply for a domain name to the extent that there is no interference with the competence of ICANN. The initial Members of the DAC are IATA (International Air Transport Association), ICAO (International Civil Aviation Organization), ACI (Airports Council International) and SITA (Société Internationale de Télécommunications Aéronautique).

2. Reference: Annex K: Reserved Names (New TLDs agreements with ICANN)
http://www.icann.org/tlds/agreements/unsponsored/registry-agmt-appk-26apr01.htm

> B. Additional Second-Level Reservations. In addition, the following names shall be reserved at the second level:
>
> - All single-character labels.
> - All two-character labels shall be initially reserved.
>
Ø The reservation of a two-character label string shall be released to the extent that the Registry
Ø Operator reaches agreement with the government and country-code manager, or the ISO 3166
Ø maintenance agency, whichever appropriate.
Ø The Registry Operator may also propose release of these reservations based on its implementation of measures to avoid confusion with the corresponding country codes


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