March 23, 1998


Via Hand Delivery

The Hon. Larry Irving
Assistant Secretary of Commerce and Administrator
National Telecommunications and
Information Administration
U. S. Department of Commerce
Washington, DC 20230

Re: Improvement of Technical Management of
Internet Names and Addresses
Docket No. 98212036-8036-01

Dear Secretary Irving:

The American Association of Community Colleges (AACC) is the major national organization representing the nation's 1,113 public and private degree granting community, junior and technical colleges. AACC's member institutions enroll approximately 5,500,000 students throughout the United States. On behalf of AACC, I am pleased to submit these comments in response to the National Telecommunications and Information Administration's (NTIA) February 20, 1998 request for comments on its proposal for Improvement of Technical Management of Internet Names and Addresses. Community colleges are among the leaders in utilizing the Internet to deliver education and training to students on-campus, across town, across the country and across the world. Community colleges have registered countless Internet domain names that use the .edu generic top-level domain (gTLD). Therefore, they have a deep interest in the issues raised in this proceeding and commend NTIA for the approach and priority it has given to addressing some of the significant problems associated with management of the domain name system.

We support efforts to insure the fair and equitable management of the Internet as its growth continues to accelerate. We support the proposal to transfer management of the Domain Name System to a private nonprofit corporation, and welcome NTIA's call that the new system must, in part, assure stability and avoid disruption of current operations. We also applaud the proposal that the new technical management of the Internet must reflect the diversity of its users and their needs by having balanced membership representing the major Internet stakeholders.

With regard to this last point, NTIA's proposal states that it will "shift operation of .edu to a not-for-profit entity." AACC believes that a shift in operations should not change who is entitled to use the .edu gTLD. Accordingly, AACC believes it is vital that NTIA make clear that existing college and university users of the .edu gTLD must be grandfathered under any new system that ultimately is identified, and that this grandfathering will enable current .edu users continued use the .edu gTLD as their appropriate services expand. The new registration system should not become a vehicle that divides higher education into higher and lower division institutions with only some institutions being entitled to use the .edu gTLD. Failure to clarify the scope of grandfathering will disrupt long established communications patterns established by community colleges and other higher education institutions. We also urge NTIA to specifically identify community colleges are one of the major Internet stakeholders and that accordingly, one or more community college representatives should be named to the board of the new not-for-profit entity that will administer the .edu gTLD.

AACC would be pleased to answer any questions you might have concerning this pleading or to provide any assistance to NTIA as it develops its final Internet Domain Name System reform position.




David R. Pierce