From: CHRISTINE RAY <CRAY@email.usps.gov>

To: " (052)usdomain(a)ntia.doc.gov" <usdomain@ntia.doc.gov>

Subject: United States Postal Service response to .us RFC

Date: Mon, 17 Aug 1998 17:24:57 -0400

August 17, 1998

Karen Rose

Office of International Affairs

National Telecommunications and Information Administration

Room 4701

U.S. Department of Commerce

14 Street and Constitution Avenue NW

Washington, D.C. 20230-0001

Dear Ms. Rose:

The United States Postal Service (USPS) respectfully submits its comments to the National Telecommunications and Information Administration (NTIA) on the enhancement of the .us Domain Space as described in the Federal Register released August 4. The USPS commends NTIA's leadership on these issues and welcomes the opportunity to provide its comments.

Enclosed is a hard copy of the Postal Service's response and a disk with a Word document, version 7.0.

An electronic filing via email is also being submitted.

Sincerely,

//s//

Allen Kane

Enclosure

Before the

DEPARTMENT OF COMMERCE

NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION

Washington, D.C.

Request for Comments on the

Enhancement of the .us Domain Space

Docket No. 980212036-8172-03

COMMENTS OF THE UNITED STATES POSTAL SERVICE

Pursuant to the Public Notice released August 4, 1998, the United States Postal Service ("Postal Service") respectfully submits its comments to the National Telecommunications and Information Administration ("NTIA") on the enhancement of the .us Domain Space. The Postal Service commends NTIA's leadership on these issues and welcomes the opportunity to provide its comments.

I. Introduction

In response to the "Request for Public Comment on the Enhancement of the .us Domain Space," the United States Postal Service is prepared to coordinate the administration of the .us Country Code Top Level Domain (ccTLD) with direct input and participation from Internet stakeholders. Throughout the history of the United States, the Postal Service has played a pivotal role in supporting infrastructure to ensure universal delivery of correspondence and commerce for the nation. In the 1770s, the Continental Congress established the Post Office to help bind the new nation together, support the growth of commerce, and ensure a free flow of ideas and information. Two centuries later, the Postal Reorganization Act of 1970 reaffirmed the mission of the Postal Service "to bind the Nation together through the personal, educational, literary, and business correspondence of the people." By coordinating the organization, development, and administration of the .us ccTLD on behalf of this nation's residents, the Postal Service will continue its mandate to facilitate correspondence in the 21st century and beyond.

II. Attributes for Coordinating the Administration of the .us ccTLD

Administering ccTLDs needs the leadership of an organization that has multiple attributes:

A firm commitment to public service;

Trusted status and credibility with key stakeholders;

Fair and open decision making procedures that are subject to public scrutiny and input;

The ability to coordinate administration of the .us ccTLD on a cost recovery basis;

The ability to facilitate access to an efficient and equitable dispute resolution process; and

Resources to manage domain name administration and technical issues.

- 2 -

III. The Postal Service's Capabilities

The Postal Service is uniquely qualified to foster widespread personal and commercial use of the .us ccTLD and commit resources to coordinate the administration of the .us ccTLD. Specifically, the Postal Service:

Can maintain consistency of policy across .us ccTLD and preserve its mandate to serve the public;

Has built a bond of trust with the people it serves by ensuring privacy and security of correspondences;

Has a system of public oversight and is subject to inquiry by Congress. The Postal Service is an independent establishment of the executive branch, subject to sunshine and public disclosure guidelines that provide public input to Postal Service policies. It is able to utilize the Federal Register Notice process as a vehicle for receiving public comments from stakeholders about proposed rules and operations.

Has a history of developing public infrastructure on a cost recovery basis;

Has demonstrated expertise in managing information infrastructure. It manages and keeps current a database of 135 million physical addresses for which it has responsibilities under law and tradition for protecting privacy. Additionally, the Postal Service has one primary and 16 secondary domain name servers which handle over 125,000 host names using a Class A IP license (a license to use over sixteen million IP addresses).

IV. Proposal to Coordinate the Administration of the .us ccTLD

The Postal Service will coordinate with Internet stakeholders the development of fair and open policies and procedures for administering .us ccTLD. This will include, but is not limited to:

Applying the Postal Service knowledge of fair and effective governance structures that support decision making and robust deliberation among stakeholders. One example is the Mailers Technical Advisory Committee (MTAC), a forum for mailers to participate in relevant decision making processes;

Leveraging the Postal Service's experience in large-scale information systems management to facilitate development of a robust and efficient domain name structure within .us ccTLD;

Maintaining current .us domain names;

V. Proposal to Enhance the .us ccTLD

The Postal Service proposes to develop infrastructure to enable electronic commerce within the .us ccTLD. The following are several potential enhancements:

The Postal Service could provide universal, private, and secure electronic addresses for all residents in the United States;

The Postal Service could enhance electronic addresses by linking them to physical delivery addresses. This would be done within its responsibilities under law and tradition for protecting privacy;

The Postal Service could combine legal protections and technology to ensure that users are able to control the flow of commercial communications through a protected address;

The Postal Service would coordinate private sector involvement in the development of a classification system for the second-level domain names. This naming system may be based on major functional groupings for businesses and other entities. Possible reference models for classification may include, but are not limited to, the Patent and Trademark Office or Yellow Pages classification systems.

VI. Conclusion

The Postal Service currently ensures the delivery of over 190 billion pieces of mail a year through its large-scale infrastructure and delivery system. It has a history as a trusted public service entity, serving all residents of the United States. If the public's interest is best served by Postal Service coordination of the .us ccTLD, the Postal Service would leverage its expertise and attributes to coordinate the .us ccTLD in a manner that would protect privacy and enhance this part of the Internet.

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From: James Sears <james@acornusers.org>

To: NTIA.NTIAHQ(usdomain)

Date: 8/17/98 12:28pm

Subject: Response to DOC NTIA document 980212036-8172-03

Response to DOC NTIA document 980212036-8172-03 "Requests for Comments

on the Enhancement of the .us Domain Space".

Q1: How should the present geographic structure of .us be extended or

modified? What changes should be made in RFC 1480 or the posted

policies for .us?

A1: The current geographical system is a useful complementary system

to non-geographical domains such as COM.US which should be

introduced in the future, and I believe the geographical domain

structure was well thought out and should be retained in it's

present form.

One addition which should be considered is reserving mail.*.*.us

(ie the subdomain mail for every delegated location in every state)

for use by non-profit companies (or local government) to provide

free web e-mail / e-mail forwarding to all residents of that area.

This would provide a useful community service, enabling addresses

such as jsmith@mail.berkeley.ca.us.

If you want to give everyone an e-mail address allowing access to

web e-mail from eg libraries is a much better idea than mapping

e-mail to postal addresses. E-mail is very different to traditional

mail and the two systems do not translate well. For example what

would happen if you were using the e-mail to normal mail system and

someone wanted to reply? With web based e-mail it's easy, they just

hit reply. Web based e-mail also has the advantage of enabling

private sector provision of the service, removing funding problems.

Q2a: What are the benefits and costs of different options for allocating

second-level domains under .us? How should the allocation of such

second-level domains be decided and administered? What should be

the terms of delegation?

A2a: The number of new sub domains should initially be limited (ie <10)

to avoid confusion. Registration of domains in all sub domains

should be operated in a strictly not for profit manner, but

registrars could of course offer value added services, as long as

people who chose not to use them were not penalised.

It is important that all sub domain registrars use a system which

is similar in appearance and use to the end user, and which is

compatible with other sub domain registrars.

Sub domains should be allocated and controlled by the USDAG, see

A9 below for details.

Q2b: Specifically, should special-purpose second-level domains be

created under .us? What are the benefits and costs of creating

particular special-purpose domains (e.g., industry-specific,

credentialing, zoning)? How should such domains be created and

administered? Are there reasons to map names and other addressing

and identification systems (e.g., postal addresses, telephone

numbers, longitude and latitude, uniform resource numbers or

others) into .us?

A2b: To some extent special purpose sub domains are a good idea, but

only as long as they are _not too specific_, and there are genuine

conditions on registration which applicatants MUST meet.

For example RADIO.US for national radio networks may be a good

idea, but only as long as it really was limited to the names of

companies which broadcast to at least a high percentage (say 90%)

of the nation. This checking would take time and money, but could

be offset by higher registration charges for specialised domain

such as these, which truly national broadcasters could afford.

Such specialised domains would have to be considered by the USDAG

(see A9) once the US domain expansion to included COM.US etc had

been evaluated.

I was originally going to use TV.US and national television

broadcasters as an example here instead of radio. However two

letter sub domains are not a good idea along side the existing

state sub domain system, and so should be avoided. An alternative

such as TELE.US or TVN.US would have to be used instead.

Mapping domain names onto other existing numbering or location

systems is a backward step. Domain names are much easier to

remember than arbitrary phone numbers. To create a vast number of

domain names simply to mimic other less advanced location system

seems a total waste of time.

TPC.INT <http://www.tpc.int/> has already mapped all phone numbers

to domain names for use in an e-mail to fax gateway. However to

create a hierarchy with structure the following system is used:

eg 1-234-567-890 becomes 1234567890.iddd.tpc.int becomes

0.9.8.7.6.5.4.3.2.1.tpc.int

Which is hardly easy to remember or to tell someone ("zero dot,

nine dot, eight dot, seven dot..."). The TPC system is useful for

computers to use in an e-mail to fax gateway, but no one would

consider using it for a web site or e-mail address.

While a unique ID, such as social security number, based domain

system, eg under SSN.US, might have some benefits, a flat domain

structure with every number directly under SSN.US would create a

zone file so large as to be unmanageable. Such domain names would

also have little value to people, as they would be harder to

remember than name based systems, and so would probably end up

being used exclusively by computers in transparent transactions.

The domain name system was developed so that people did not have to

use numbers (IP numbers) but could instead use names.

Creating credentialed zones at a national level (ie directly under

.US) does not appear to be a good idea, as many organisations which

may qualify for such domains would not be national in scope.

The existing structure of the US domain was very complex, and while

the aims and ideas were excellent people didn't use it, preferring

COM and other simple TLDs. For the expansion of the US domain to

be successful it should start with the addition of simple sub

domains (see A2c below) which people will use, not complex mapping

systems.

Q2c: Alternatively, should .us be treated as an unrestricted top-level

domain like .com or should one or more specific second-level

domains such as .co.us or .com.us be used for unrestricted

assignment of domain names (as in .com)? How should such

unrestricted domains be administered and by whom?

A2c: Making .US an unrestricted domain with registrations directly

below it is a very bad idea. It would be confusing, there would be

a rush for domain names, it would make the existing geographical

and any new sub domains almost impossible (ie how does someone know

the difference between an official sub domain such as ca.us and

a company eg ge.us).

Generic second level domains, eg COM.US, are a good idea, and such

domains can exist along side specialised sub domains such as the

existing geographical sub domains and any new industry domains such

as RADIO.US.

To avoid confusion with COM etc it might have been a good idea to

use CO.US and not COM.US. However as all two letter sub domains

under US should be reserved for states (and future states) this is

not possible, although the USDAG (see A9) could consider special

exceptions where really necessary.

The following generic sub domains, already used in many other

countries, should be considered in the first phase of .US

development:

COM.US, for commercial entities, an alternative to COM.

INC.US, for incorporated companies (see below).

EDU.US, for Universities, an alternative to EDU.

ORG.US, for national organisations, an alternative to ORG.

GOV.US, for federal government, to replace GOV and FED.US.

MIL.US, for the military, to replace MIL.

NET.US, for ISPs (see below).

Careful thought needs to be given to which generic sub domains can

be created. Generally only when registrants under such a sub domain

are national in scope should the sub domain be considered, with

sub domains which would attract local registrants (eg SCH or K12)

placed under the existing geographical sub domain structure.

Also strict rules are necessary to ensure that domain names in such

sub domains are only registered by entities which actually qualify.

This will take time and money, but it is a price which has to be

paid to maintain order, something that InterNIC has not managed to

do with regard to COM/NET/ORG TLD distinctions.

Rules are especially necessary for NET.US, which would be used for

networks and network infrastructure entirely in the US, or for

parts of global networks in the US. However the NET.US domain MUST

NOT be allowed to degrade into a substitute COM.US, as has happened

with the COM/NET TLDs. Registrants in NET.US must be required to

prove they are really an Internet service provider, that any

machine in the NET.US domain is online permanently, that customers

will never be given an e-mail address using NET.US, and that the

requested domains under NET.US accurately reflects the name of the

incorporated company requesting registration. (See guidelines for

NET.UK at http://www.nic.uk/domains/net.uk.html for an example.)

This extra checking may require addition time and money, but can be

met by higher registration costs for this sub domain.

A sub domain INC.US for nationally incorporated companies to

register under would ensure that every company could have a domain

name which matched their company name. In function it should be

similar to LTD.UK/PLC.UK, ie that only registered companies may

apply for a domain name, and that the name must be the same as the

name under which they are legally incorporated.

Note also that I believe that MIL should be replaced by MIL.US and

GOV by GOV.US (but COM/ORG/NET would NOT be replaced by similar US

sub domains, simply exist as an alternative). Not only is this more

appropriate in today's global Internet, it also often makes more

sense to associate US with department names. MIL and GOV should be

phased out of active use as soon as possible, although existing

domains will have to be kept alive for several years to redirect

e-mail and web requests to the new MIL.US and GOV.US addresses.

COM is not a TLD for US companies, it is a TLD for companies from

any country. It is important that US companies have a geographical

domain that is not too complicated which they can register in,

ie COM.US. Even though CO.UK exists many UK companies use COM, and

similarly even though COM exists many UK companies use CO.UK. It

is up to the company to decide if national identity is important,

perhaps they will register both names and use one for a corporate

overview site and country code registrations for local

subsidiaries.

Additional sub domains, including any specialised ones such as

industry identifiers, or any similar to the proposed new gTLDs

(eg SHOP.US, REC.US), could be considered by USDAG after the

initial implementation of a limited number of generic sub domains

has been evaluated and the registrar system is tried and tested.

Q3: How should conflicting proposals and claims to manage or use .us

subdomains be resolved? Who should have responsibility for

coordinating policy for .us over the long term? What public

oversight, if any, should be provided?

A3: The US domain should be managed by a private, not for profit,

organisation, referred to in this document as the US Domain

Administration Group (USDAG, see A9 below).

Proposals for new sub domains would be evaluated by the executive

of the USDAG and voted on by members.

The USDAG is answerable to it's members, and other than standard

membership of interested government departments who joined in the

same was as others, the government should have no control over, or

special representation in, the USDAG.

Q4: What rules and procedures should be used to minimize conflicts

between trademarks and domain names under .us? Should this problem

be treated differently at international, national, state, and local

levels? Should special privileges be accorded to famous trademarks,

such as a right to register directly under .us or a procedure to

preempt the use of the trademark in a range of subdomains?

A4: Trademark issues can generally be dealt with under existing laws.

However it may be a good idea to implement a dispute resolution

policy similar to that proposed CORE/gTLD-MoU and WIPO

<http://www.gtld-mou.org/docs/dispute.html>, eg registrants can

optionally wait a period of time after applying for a domain name

before completing registration, to allow for any objections to be

made. Also some form of optional arbitration, for registrants

wishing to avoid the courts, should be made available by the USDAG.

There must be absolutely no privileges for "famous" trademarks, and

no company must ever be allowed to register directly under .US when

official sub domains for registration such as COM.US exist. This is

as bad an idea as allowing companies to have their own TLDs. The

hierarchy of the DNS exists for a reason, to flatten the structure

by allowing some companies the same position as gTLDs or ccTLD sub

domains is a very bad move.

If a company wants to stop people using their trademark in generic

sub domains they just register it themselves normally, as currently

happens with the 200 or so ccTLDs. However for location sub domains

a different strategy may be needed, as long as it did not prevent

legitimate use of a domain (eg an individual who was called

Mr Ford and who lived there may want to register a domain name

ford.berkeley.ca.us). This issue will need careful consideration

and almost certainly a case by case consideration, something for

the USDAG to implement.

Q5: What role should states play in the allocation and registration of

their respective subdomains? Should commercial names be permitted

under states as third-level domains? Or should such third-level

domains be limited to special categories such as domestic

corporations or other state-licensed entities? Should states and

localities operate registries and accept registrations directly?

To what extent should state policies be coordinated and through

what mechanisms and procedures?

A5: State sub domains should be administered in the same was as all

other sub domains, by the USDAG (see A9 below). Companies should

not be able to register directly under state domains, unless they

are verified as having substantial activity (eg offices) in at

least (USDAG to set some high percentage) of that state, and are

local to that state. Even so it may not be appropriate to allow

third level registrations, the USDAG and local registrar would

have to reach a decision.

Q6: How well has the system of delegating third-level domains

(localities) to private registrars on an exclusive basis worked?

How could it be improved? Should registrars be accountable to their

delegated localities (just as country-code registries are

accountable to national governments)? Should registrars be limited

to a single jurisdiction? Should multiple competing registrars be

able to register under any local, state, or special-purpose domain

under .us as in the plan proposed for generic Top-Level Domains?

A6: Third level registrars should operate in a similar way to second

level registrars, and they should be answerable only to the USDAG

(see A9 below). As long as registrars operate the registration

service on a not for profit basis then a single registrar serving

large areas is not a problem, subject to USDAG approval.

Any complaints against a registrar should be dealt with by the

USDAG, who may choose to assign a new registrar.

Q7: How should the operation of the .us registry be supported? Should

uniform registration (and renewal) fees be instituted? Should

registrars contribute to the operation of the registry?

A7: All registrars should operate registration on a not for profit

basis (see A9 below). Second level registrars should contribute to

maintenance of the USDAG (along with USDAG membership fees).

While some registrars may be able to offer free registration, most

will charge a low fee, either a one off, or yearly. Such fees

should be capped by the USDAG, and can in any case not rise too

high while registrars are operating in a non profit making manner.

Q8: What are best management and allocation practices for country-code

domains? What practices should be emulated or avoided?

A8: The UK system <http://www.nic.uk/> works well in general, however

it does not have the global accessibility that InterNIC does,

limiting some features to companies which have registered to obtain

a tag.

InterNIC's system of e-mail updates, where anyone can register a

domain, and can update their domains, is open and efficient, and

that is very beneficial.

Allocation of domains directly under a country code is ok for

small countries and where Internet use is low, but is not really

appropriate for countries with large computer using populations

where hundreds of thousands of domains will be registered, as is

the case in the US.

Some smaller countries implement a policy where domain registrants

have to agree not to abuse the network, eg by sending junk e-mail

or spam, and if they do their domain name is deleted without

refund of the registration fee. Junk e-mail is a real problem and

this method of removing junk e-mailers is a good idea. In addition

the USDAG could undertake legal action against junk e-mailers who

forged .US e-mail addresses or domain names.

Q9: By what type of entity should .us be administered? Private,

governmental, or quasi-governmental? For profit or not-for-profit?

What are the advantages and disadvantages of using one type of

entity (private, public, for profit, not-for-profit) over the

others?

A9: A private, not for profit company, reffered to here as the US

Domain Administration Group (USDAG), should be established to

oversee the entire US domain name, delegating sub domains where

appropriate to similar organisations (ie usually private, not for

profit), and maintaining others it's self, much like Nominet in the

UK. In addition the USDAG could coordinate other issues of the DNS

which effect the US, possibly representing US interests in the new

gTLD organisation.

Membership of such an organisation should be open to everyone who

pays the annual membership fee, although the membership is likely

to be largely ISPs and other companies involved in the Internet.

As non-US companies may have an interest in the US domain (eg

registering names for clients) they should probably be allowed to

join, although the membership will be dominated by US companies.

A not for profit organisation owned by it's members, the people

with the most interest in the US domain, is beneficial for several

reasons. It is open and accountable, anyone can join, everyone who

joins has a vote. As it is not concerned with making a profit and

membership is not restricted it can be trusted not to abuse it's

power. And as it is not a governmental organisation it requires no

public funding, and will remain stable over years while governments

and/or their policies may change.

As well as providing administration for various issues connected

with the US domain, assigning sub domain registrars, maintaining

the US domain primary DNS server, etc, the USDAG will serve as a

ombudsman/regulator, ensuring that registrars conform to USDAG

guidelines and operate in an appropriate manner.

Sub Domains

The USDAG will be responsible for determining what sub domains

should be created, how they will be run, and who will maintain

them. Registrars will be appointed for some sub domains, while the

USDAG may perform that function for others (eg NET.US which

requires few additions but more checking).

Registrars which are appointed to manage sub domains can do so

exclusively, because the USDAG will require them to register

domains without making a profit (even if other parts of their

business are profit making), and without prejudice, and so

multi registrar competition would not have many benefits, while

increasing complexity of the system.

Although registrars must be required to charge minimal fees for

registration and not to make a profit from registrations, they

should be allowed to sell value added services, as long as users

can register domains without using purchasing services as easily

as those who did. This will not only encourage companies to provide

registration services, which they do without making a profit, but

also to actively promote the new US sub domains.

To prevent registrars having too much influence because of their

position as a registrar the official web site for registering

domains should be kept separate from the registrar's commercial

site. For this purpose the domain name "nic" under every sub domain

must be reserved for use by the registrar, for the sole purpose of

providing simple registration services. Any references on this

special site to value added services must always include examples

other than those offered by the commercial interests of the

registrar. eg www.nic.com.us is reserved for the COM.US registrar.

This also has the benefit of the registration and information

site for each sub domain remaining unchanged even when registrars

change, and being at a predictable address.

To ensure ease of use for users of the US domain registration

process the USDAG should set down guidelines that sub domain

registrars should follow in other areas. For example the

registration procedure should be standardised, so that once

someone has registered one US sub domain they will know how to

register another under any other US sub domain.

--

James C N Sears <james@acornusers.org>.

Salisbury, United Kingdom. 17th August 1998.

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