Well done!

[Gordon Irlam <gordoni@base.com>]

The draft guidelines appear solid well thought out guidelines for
ensuring the transition to a fair and open competitive DNS registration
framework.  Well done!

Some specific minor comments on the proposed accrediation agreement
terms:

IV: SLD holder initiated change of registrar.  To ensure vigorous
competition, an SLD holder need to be able to instigate the transfer of
their registration from one registrar to another.  A set of
responsibilities and requirements needs to be imposed on registrars to
ensure this is possible.  This issue is not currently addressed by the
guidelines.  There are two seperate issues that need to be addressed:
security and verification guidelines to ensure such a transfer isn't
done without the clear consent of the SLD holder; and operational
guidelines for performing such a transfer.

IV.3: Registrar initiated removal of registration.  A mechanism needs to
be in place to enable a registrar to remove an existing registration
that they administer ahead of the original expiration date.  This might
need to occur in response to a bounced check, or some other breach of
contract by the SLD holder.  Perhaps an update with the expiration date
set to the current date is sufficient to effect this.  If so, this
should be spelled out.  To incent registrars to collect reliable data no
refund in ICANN/registry fees should be made to the registrar as a
result of such an operation.

IV.3.a: Date and time of transaction.  Without knowing the details of
the shared registry system, an additional data element might be
considered that specifies the date and time a request was considered to
have been received and performed by a registrar.  This may prove
necessary for disambiguating requests from different parties for the
same SLD, or in the case that an existing SLD owner submits multiple
changes to their registration information in near succession.

IV.5: SLD owners may forget the identity of their registrar. 
Consequently the rights in data need to be expanded to at the very least
ensure the SLD owner can use whois or some other central service to
rediscover IV.3.iv, in order to be able to contact their registrar and
update their registration information.

IV.9.d: Guidelines should not assume or require that registrars must
operate using a registration fee based business model.  The Internet is
replete with people attempting alternative revenue models including
advertising based, subscription based, commission or pass through based
models, and bundling of goods and service based business models. 
Registrars should be free to attempt such business models so long as
they are willing to commit to and abide by the other guidelines.


Keep up the good work,
Gordon Irlam
(base.com SLD holder)