From: Bob Kirkpatrick <bobk@dogear.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/23/98 9:42pm

Subject: US Domain RFC

Ms. Rose: I am a US Domain Registrar Delegate, and was one of the first to volunteer my services. I currently operate the USD DNS systems for the five northern counties of Idaho, and Spokane and Pend Oreille counties in Washington state. I would like to respond to the Request for Comment regarding US Domain operations.

First, I have seen suggestions that the US Postal system take over responsibility for some of the US Domain activities. On one hand, I thik this wise, on another, I think it could be disasterous.

Were the postal system used so that registrants could walk into any post office and obtain registration or modification forms, and have someone there to help them complete those forms, that would be great. Kept entirely local and de-centralized, the US Domain could continue to be

quickly and efficiently responsive to requests. Currently, the domains I operate have an average turn-around time of five to eight hours for creations, modifications or deletions. We are continually complimented for this, especially in light of the fact that no other domain system is able to be as responsive. Our registrants tell us they are pleased that we can complete any operation in less time than it takes InterNIC to acknowledge receipt of change requests.

Were the postal system to offer centralized root servers, that would be a boon. The current system has a number of problems which come from funding and other administrative issues which are not the fault of those operating it.

It is crucial that the US Domain maintain local administration of the DNS systems. It was a terrible mistake to permit the use of domain 'companies' that have no interest or stake in the domain parks. For a resident of the west coast to have to go to Connecticut for DNS work is and has been ludicrous and wasteful. We are currently operating DNS for a number of companies and individuals who found their geographic territory the meal ticket of remote and unresponsive delegates. So we folded them under our wings so they could get the service they both need and deserve.

It was an error to create parks within parks. By having cities and towns within a particular county unable to figure out who their registrar is, and then having difficulty in communicating, has caused the US Domain to lose many potential registrants to the NSI controlled TLDs.

An individual, business, town, school, or government body within a county should be registered under a single domain park, regardless of whether or not the secondary domain is preceeded by ci, co, k12 or other ancillary identifiers.

Were the US Domain permitted a budget to advertise with, much of the 'anonymous' qualities of the US Domain would dissipate. Additionally, with many states now attempting legislation against unsolicited commercial email (SPAM), and some with legislation in place, registrants in the US Domain would have additional protection by virtue of their location shown clearly in their domain name. This type information should be made available both to those who originate SPAM and to those who do not wish to receive it, or have their resources conscripted by it. Advertising would go a long way to allowing this information to get into the hands of those who need it.

Even today, with geographic domains immediately recognizable to neophyte internet users, many still don't know the US Domain exists. Many who do know it exists, mistakenly believe that it is for government entities only, and are surprised to hear they can use it too.

In conclusion, I would hope that the US Domain look strongly at maintaining local administration, maintaining all US DNS activities within a county under the county park alone, and advertise the existence of the US DNS system. It would be wise to permit the USPS to *assist* local delegations in servicing the clients, yet not absorb or encapsulate the US system, and attempt to operate it entirely.

Thanks for the opportunity to communicate my views.

Sincerely,

Bob Kirkpatrick, US DNS Delegate

bobk@dogear.com (509) 456-3353

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From: Bob Kirkpatrick <bobk@dogear.com>

To: NTIA.NTIAHQ(usdomain)

Date: 8/23/98 11:51pm

Subject: REPLY: USPS takeover of the US Domain

I would like to respond to the USPS offer to take over the complete operation of the US DNS system.

1). REGULATION. The internet is a free marketplace. While it has a few inconveniences, such as unsolicited commercial emails, and some web sites which violate the personal codes of some individuals, it has been proven in court and practice that any attempt to regulate the medium would have a chilling effect on the marketplace and would stiffle freedom of expression.

As an arm of the United States government, the US Postal system would be forced, at the whim of current administrations, to effect chilling regulation upon the internet and it's users. Anyone who peruses the USPS Codes will see radiant examples of this already applied to ground mails.

If any single concept applied to the internet is horrific, control of as large a segment of the internet as the USPS desires to assume is it.

2). RECOURSE. The USPS is virtually unapproachable for complaint. While the USPS proudly touts it's prosecution of those who interfere with the mail system, it neither reprimands nor prosecutes it's own employees when they violate the laws claimed sacrosanct by the System. I have significant personal experience with this, having personal mails discarded by disgruntled carrier(s) and that offense ignored by Postmasters not wishing to bring notoriety to their sphere of operation. I admit that this is a significant accusation, but it is documented and verified. All attempts to approach the USPS for rectification were ignored.

3). COMPETENCE. The US Postal system is the brunt of many, many well deserved jokes at it expense. Most people cannot refrain from making rude or sarcastic remarks in response to USPS advertisements for Priority mail. While the USPS desires to be competitive with private sector delivery companies, it's a well known fact that they are not competitive, with Priority mails delivered not in 3 days, but often in excess of a week or more. Only last year it was revealed that the USPS in Spokane, Washington lost over two tons of Priority mails for a period of four months. (see: the Spokesman Review newspaper). Local workers admitted to interviewers that this was only an exception to the rule by virtue of the quantity of lost mails (stored in a dumpster), but that it was the rule that Priority mails were more often than not delivered late.

4). REDUNDANCY AND NAMESPACE. The USPS is offering to assign 'private and secure US Domain email addresses to everyone in the United States.' (paraphrased). This is simply unrealistic. Already, InterNIC is laboring under a namespace load considerably less than the population of the entire nation. For the USPS to claim that they have the magic to succeed --and with such a cavalier attitude, should be considered as a warning shot to everyone who hears the claim.

Not everyone in the United States wants a US Domain assigned to them. If they did, they would want control over what that name is, and not have it forced upon them by an agency impossible to attain redress from. This further has anonymity ramifications for people who are 'hiding' from

abusive spouses, stalkers and other entities. Once an email address has been used, it will, in this particular case, draw a neon pointer to the holder of that address. This is in direct conflict with the USPS assertion that an email address can be secure. It is pretty obvious that the USPS does not understand the medium they wish to control.

CONCLUSION: If the USPS wishes to offer the US Domain access to it's considerable equipment resources, but under the control of non-government and approachable registrars, then great. But even this short treatise raises constitutional issues, security issues, and some very obvious adminsitrative issues. Great caution needs be used when giving a government agency such incredible power over such a dynamic and free resource like the internet.

We respectfully hope that the NTIA will give this the concern and attention it deserves. Once in place, it's too late to go back. I would hate to think that the (perhaps) well-intended offer of the USPS would end up driving internet users to other geographic and Top Level Domains offered by other countries and agencies. If the intent of this RFC is to truly determine the best course for the US Domain, then it should decline the offer of the USPS.

Bob Kirkpatrick, US Domain Delegate

bobk@dogear.com (509) 456-3353

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