From: "Bruce O. Benson" <benson@sparta.com>
To: NTIA.NTIAHQ(usdomain)
Date: 8/10/98 2:01am
Subject: Comments on Enhancement of .us domain space
Ms. Rose,
Please accept my following comments on enhancement of the .us domain
space.
My responses are organized numerically in correlation with the Questions
for Public Comment.
1. The geographic structure of .us is sufficient. All my suggestions
would expand the .us domain while remaining fully compatible with the .us
TLD in place.
2. I propose to expand .us to include commercial subdomains for .com.us
(or a .co.us) as well as the states as .com.va.us (for example). The cost
will be borne by the registrants and administered by InterNIC for .com.us
and for an authority set up by each state for .com.state.us. Each state
could then decide how costs should be borne.
Additionally, I strongly suggest a subdomain for U.S. Citizens, .per.us or
something similar. This would allow a simplified redirection of IP
requests to the user and follow him/her during relocations. A similar
convention could be allowed for at the state level for state residents.
Costs would be minimal and borne
by the personal user, delegation could be performed by any number of
existing non-profit authorities, but my personal favorite would be the
U.S. Postal
Service. This would allow a single change-of-address form to be used as
well as encouraging the USPS to commence a no-frills email service. If
changing your surface is free, shouldn't changing your Internet Address be
free (or nearly free) as well?
3. I do not suggest any other subdomains be created other than .per.us,
.per.state.us, .com.us, and .com.state.us.
Further subdomains are unneccesary branches from these and create
additional delegating authorities which would heavily complicate the
existing DNS. Imagine someone typing URL://703-448-0120.us to get to my
voicemail. The named daemon would have a huge parser to differentiate
this from URL://78.80234+37.890.us and all the other types of urls. It
would be better to let software engineers craft special daemons to serve
the needs of telephonic or geocoordiated URLs.
Just going through the exercise of simulating a telephonic or
geocoordinated URL reveals the lack of orthogonality of appending .us
afterwards. This begs the question of whether telephonic or geocoodinated
URLs should be TLDs. That is not a question that should be discussed
here.
4. .us should not be unrestricted, as suggested by aforementioned
comments. Delegation is mentioned in previous comments as well.
5. The top level .us domain should be administered by the United States
Government. This would ensure proper maintenance of subdomains for states
and citizens. This requires minimal registry database, as all the heavy
work for .com.us is borne by InterNIC. And all the .per.us would be borne
by a separate delegating authority as well.
I believe this would be the FCC's job to administer this TLD.
6. .com.us domains are issued first-come, first served. It is very hard
to make domain holders give reference to a different trademark holder of
the same name and should not be required. The delegating authority should
treat each entity requesting a name as if it were requesting a street name
(in the case of a .com.us domain) or a personal legal name change (in the
case of a .per.us domain). Can a copier company get a street name 'Xerox
Road'? I don't know, but this is the analogue of precedence.
When applying for a .foo.us domain, Federal laws prevailing over the
analogues are applied. When applying for a .foo.state.us doamin, state
laws will prevail.
7. Each state may administer/delegate it's own sublevel as it sees fit.
This settles the important states-rights issue once and for all. The
presence or absence of any DNS service within a .state.us subdomain would
completely be the responsibility of the state. It would be possible for
some states to have free state-provided URLs for all comers, while others
delegate the assignment to profit-taking corporations.
State government domains would be pointed to by DNS listings maintained by
the U.S. Government delegating authority (i.e. the FCC).
8. I think the current system of delegating third-level locaility domains
to private registrars is poor. It is not possible for an individual to
be assured he/she could receive a low-cost or free domain listing. This
is a simple service that can be performed very inexpensively or freely by
the quasi-government and quasi-states entities (a la USPS, Amtrak, power
companies, etc.). Some states could actually appoint volunteer
authorities for certain locality domain delegation as they see fit.
Conversely, I doubt the United States could issue up to 250M+ .per.us
domains without substantial cost. The gist of my argument is that profit
motive should be removed from non-commercial delegation wherever possible.
9. Because of the sparcity of top level .us doamins (one pointer for each
of the states,
territories, and a single pointer to the .per delegating authority, and
pointers to U.S. Government departments) this
would be a low-cost administration of the FCC.
10. This issue should be left to the United Nations.
11. To summarize:
.us--FCC
.co.us--InterNIC or someone like them.
.per.us--quasi-governmental/non-profit.
.co.state.us--a state-appointed authority as they see fit.
.per.state.us--a state-appointed authority, non-profit, or free.
.gov.state.us--state government.
Feel free to contact me for further comment or explanation.
My opinions may or may not reflect those of my employer, who provides my
email service. My comments are offered in a professional but onofficial
capacity as a practicing electrical and formet network and wireless
engineer.
Thanks for the opportunity to comment.
All the Best,
Bruce O. Benson, Electrical Engineer,
SPARTA, Inc. CPD
7926 Jones Branch Drive, Ste. 900
McLean, VA 22102-3303
703-448-0210 x. 211
benson@sparta.com
###
Date: Mon, 10 Aug 1998 11:28:50 -0600
From: Brad Pierson <bpier@cfer.com>
To: usdomain@ntia.doc.gov
Subject: Comments on the Enhancement of the .us Domain Space
Brad Pierson
9051 Holland St
Westminster, CO 80021
piersonfamily@uswest.net
Simply put, the Federal should not be involved in this issue. There is no legitimate reason stated in the US Constitution for the executive branch to control or define this function. This merely gives the Federal government another avenue to pry into the private activities of citizens.
###
From: Chuck Clemens <eo11@mychoice.net>
To: NTIA.NTIAHQ(usdomain)
Date: 8/10/98 9:51am
Subject: universal e-mail
Pursuant to an article on cnn.com this am I believe assigning an e-mail
address to every US citizen would be impossible and foolhardy. I furter
would be adamantly against using said addresses to send mass information or
personal information to individuals expecting that they would have or gain
access to the means to respond to same.
Charles Clemens
Student Health Program
Southern Illinois University Carbondale
Carbondale, Illinois
62901
###
From: "Fabio M. Zambelli" <fmz@usa.net>
To: NTIA.NTIAHQ(usdomain)
Date: 8/10/98 2:59pm
Subject: Enhancement of the .us Domain Space
Hello Karen,
I cannot say anything about the proposal 'cause I'm italian and I'm not
involved in the discussion, but I would like only to say that open to
everybody a public discussion about these kind of things is a great proof
of your democracy.
Have a nice day.
> ============================================ <
> F A B I O M. Z A M B E L L I <
> ============================================ <
> vicolo San Martino # 6 <
> Pero, Milano - 20016 <
> ITALY - EUROPE <
> ============================================ <
> PHONE (international +39): 02.3810.2645 <
> FAX (international +39): 02.3810.2645 <
> [fax: dalle 14,00 alle 16,00 giorni feriali] <
> [fax: from 2 pm to 4 pm C.E.T. working days] <
> ============================================ <
> E-MAIL: <mailto:fmz@usa.net> <
> ============================================ <
###
From: <frburton@scif.com>
To: NTIA.NTIAHQ(usdomain)
Date: 8/10/98 1:15pm
Subject: Universal email
I favor the added .us domain if it means universal email for all and more
efficient use of the Internet.
Frank Burton
Phone number: (213)954-5609
Fax number: (213)954-5692
###
Date: Mon, 10 Aug 1998 08:55:07 -0400
From: LARRY FRIDAY <friday.l@nypa.gov>
To: usdomain@ntia.doc.gov
Subject: USPS Proposal Viewpoint
While the idea of a USPS email backbone linking my physical address to and electronic one is a nice idea ... however, I can see some of the following happening if this backbone was approved.
I will make a broad assumption that electronic mail would be an option that could be exercised - not a mandatory change-over.
First, laws regarding electronic mailing would need to be reviewed at all judiciary levels to verify the usability of electronic data in court. How long would this take? This should be done *before* any enactment of an email system country-wide. Let's not be revamping laws after the fact ... think ahead.
Secondly, what costs for upgrading software and hardware to generate electronic billing records are going to be passed on to the consumer? Myself, I really would not like my phone bill or electric bill to take an increase for something like this. They are bad enough as it is. Will credit card interest rates go up a point to offset the same changes? While I realize a return on investment would be preferred, I for one would not wish to see this happen to me.
Last is a concern about 'spam' - electronic mass-mailings. What happens if the USPS has an electronic version of my physical address? Will my inbox get flooded with all this 'chaff' as well? Right now, my electronic inbox is quiet and I'd really like it to stay that way, please. My physical mailbox is also reasonably peaceful with the exception of the "Resident at ..." type of mailing. I like it that way!
I appreciate what the Postal Service is trying to do and while laudable, it would need quite a bit of before-hand planning and preparation to enact in an equitable manner that would be suitable for all.
Many thanks for the opportunity of voicing my views.
Sincerely,
Lawrence B. Friday
###
From: Gary Williams <gary@gvltec.edu>
To: NTIA.NTIAHQ(usdomain)
Date: 8/10/98 11:00am
Subject: Government email envolvement
I see this more of an issue of lost revue by the post office. The Postal
Services' desire to provide an email for everyone does not appear to be for
the best interest of the consumer but rather an attempt to find some way to
recover the lost income related to email. I believe the responsibility of
government under the constitution is very limited and should be so to
protect the population from too much government intervention. Greed by
private or public institutions is destructive in any form. I say, let the
post office stick to the letter caring, package delivery (that is if they
can compete with the UPS, FedEx, and the other carriers in a cost effect
way) and help keep the government out of the Internet and email arena.
###
From: Justin Denney <jdenney@cse.ogi.edu>
To: NTIA.NTIAHQ(usdomain)
Date: 8/10/98 1:33pm
Subject: questions
3.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?
They should not be created according to physical location. One of the
benefits of networking is that it allows for physical independence.
People/companies shouldn't have to change their email address or web
address just because they change their physical location.
5.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?
.us should be the only top level domain managed by the US government.
(Other than .gov which is primarily for internal government purposes.)
6.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?
Don't issue multiple high-level names to the same company. Limit resale
of the domain name. It is terrible that in .com, some companies snatched
up common family names so that they could sell them to people from that
family. e.g. my personal example is that M@il Bank (http://MailBank.com/)
should not be allowed to own www.denney.com, as they do.
7.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?
If states are given subdomains, then they should be given full,
unregulated control over the allocation of the subdomains. But there
should first be a suggested standard for several common third-level
domains. States should accept registration directly.
9.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?
There should be a one-time registration fee. Operation should be
primarily registration, not regulatory activities, so that it remains
inexpensive.
11. 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?
Top level should be government, second levels should be private for profit
with required "watch dog" groups. Since the current proposal has been made
by the U.S.P.S., I imagine that they might be considered for some level of
administration. I think that would be a bad idea.
###
From: Kevin M Fox <kmfox@mail.bhi-erc.com>
To: NTIADC40.SMTP40("usdomain@ntia.doc.gov ")
Date: 8/10/98 1:02pm
Subject: email
Having a unique email address per postal address sounds like a good
idea. I think that the email address should be a redirector rather
than an email end. Say, for instance, that I have two houses. I could
have the one houses email redirected to the other house so I only have
one email address to look at. Also, SMime must be in place. This
allows you to confirm who you are over email and makes it unreadable
by everyone but yourself and your recipient.
Kevin
###
From: "Lon Seidman" <lon@safety-zone.com>
To: NTIA.NTIAHQ(usdomain)
Date: 8/10/98 9:42am
Subject: response
>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?
I think the universal email addresses should be keyed to their state
associations. For example, I live in Connecticut, where our .us domain is
state.ct.us (something like that). That will at least allow people to
generalize the area of the country their email is going.
>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?
That should be decided through the Internic or similar governing body, for
no cost to the US gov't for domain name maintenance.
>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?
As I stated above, state zoning should be used.. Zoning by industry will be
a haven for spammers, and it really won't prove useful. Also keep in mind
that many people already have an email address, and may not take advantage
of one if it's offered by the government.
>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?
Leave it restricted.. That will at least provide some seperation for people
on the net. I've always considered .us to belong to the nation, and not to
private organizations. com.us and other variations is too complicated.
Leave the .com.. It's already become a part of 'pop' culture.
>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?
The way it's done now, through the Internic. While there are many
complaints, they seem to be able to resolve many disputes rationally.
>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?
Again, Internic rules should apply.
>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?
Just leave it alone.. Nobody gets a .us domain unless it's a government or
government assigned email address.
>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?
No, again look above.
>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?
Again, see my previous answers.
>What are best management and allocation practices for country-code domains?
What >practices should be emulated or avoided?
What's in place now seems to work fairly well.
>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?
Internic.
###
From: "Cox, Nancy M." <NANCY.M.COX@cpmx.saic.com>
To: "'usdomain@ntia.doc.gov'" <usdomain@ntia.DOC.GOV>
Date: 8/10/98 12:34pm
Subject: .us Domain Addresses
My concern is not in reference to any of the 11 questions, but one in
general. If our e-mail addresses are linked to our street addresses, IS
THERE ANY POSSIBLE WAY THAT SOMEONE COULD DETERMINE WHERE YOU LIVE??? I
see major security issues at stake here.
Has anyone given any consideration to this EXTREMELY sensitive security
issue??? For your consideration.
Nancy M. Cox
###
From: "Richard A. Putt" <raputt@pod.c3i.saic.com>
To: "'usdomain@ntia.doc.gov'" <usdomain@ntia.doc.gov>
Date: 8/10/98 1:55pm
Subject: Request for Comments on the Enhancement of the .us Domain Space
Dear Karen Rose,
I read the CNN article "Clinton backs universal e-mail plan."
The article gave me the impression that someone in the government is
looking to establish a precedence of control over the Internet. Even
though .us TLD may not be used heavily it looks like the government is
trying to step in again.
The government did a good job starting the Internet evolution.
Also, it seemed that the government made a positive move in proposing to
pass the responsibility of DNS distribution to a private concern. The
government has done a good job at establishing the Internet as it is
today. But, history has shown that continued government involvement, in
anything other than initial development, causes problems and failures.
I see a major issue, a problem, developing if the government
allows the U.S. Postal Service to control any single Internet domain.
Although the USPS is, more or less, a private concern it is present, by
law, as an arm of the government. With this being said I do not believe
the government should continue to intervene in the operation of the
Internet in any way. Private industry has done an outstanding job in
moving the Internet into the future through the use of e-commerce. If we
allow a handful of entities to control the operation of any portion of
the Internet, within the U.S. borders, the door will be open for that
handful to dictate what can and can not be said and done over the
Internet. Trying to resolve a .us domain problem through the USPS would
be equivalent to trying to resolve a tax issue through the IRS. U.S.
citizens should consider the least level of government control in any
issue as being the best.
I read the CNN article and considered 3 different view points.
Then I continued reading about the issue by reading the proposal sent to
the Commerce Department. The prevalent opinion that I developed was one
of concern. It looks like someone is trying to make a grab for their
piece of the pie as well as a piece of controlling interest in the
Internet. If the Internet is to continue to develop at the current rate,
external regulation must be kept to a minimum. Freedom of expression is
what has allowed the Internet to grow. Granted some less than desirable
subjects are discussed over the Internet but we can't let the Chicken
Little view of the world permeate our lives.
Do not let the USPS take control of the .us or any other TLD.
Don't let any single entity, related to the government, have complete
control over a domain. Let the domain(s) evolve through open forum on
the Internet. So far, Internet users have proven to be adequate at using
the resources available over the Intent. We, the average Intent user, do
not need to be spoon fed as the legislative system would seem to lead
most to believe. The Internet is the last free frontier available to
those who need to have a place to roam without a chaperone. Let's not
ruin the Internet by placing a noose around its neck.
Greed seems to be the main impetus to the proposal sent to the
Commerce Department. The USPS wants to take control of the e-mail
industry and a great way to start is though the control of the .us
domain. The USPS and many other groups have been crying about the loss
of revenue caused by people using Internet e-mail rather than the
Shoe-Leather-Express.
Greed has driven the proposal of taxing e-mail and e-commerce.
We are already paying for the Internet in the price of our goods.
Individuals who thrive on control see taxing the use of the Internet as
the next domain to conquer.
Please, do not allow the Internet to be placed into a position
where it would be directly taxed or controlled by any government agency
or affiliate. If that were to happen I believe the Internet would die.
One question would come to mind. "Why use the Internet if it costs the
same to use the Shoe Leather Express?" I see the USPS looking at the
grand old dollar sign with no concern for the end of the free Internet.
Even the overall U.S. government would have a lot to gain
through the establishment of a whole new government organization
designed to control e-mail and e-commerce. Lots of revenue and taxes for
the government if restraints are established for the Internet. May as
well tax the Internet since everything else is taxed!!! And how would a
common everyday person, who doesn't care to know details about the
Internet, resolve problems with the new government organization? I bet
someone has an immediate answer for this one. But, the answer would not
be simple because of legal issues the everyday person would not be
answered with an expedient reply.
I just don't like the smell of this proposal no matter how it is
colored.
Sincerely,
Richard A. Putt
###
From: <SanityMad@aol.com>
To: NTIA.NTIAHQ(usdomain)
Date: 8/10/98 2:38am
Subject: Expansion of Domain
The Internet is much appreciated and I find that the investment made by our
government has been well worth the money paid. Now, however, with the
suggestion that email be supplied to everyone in American, I smell a new tax
coming.
The purpose of such a venture would have to be well defined as to it's
benefits. Frankly, I like things just the way they are. Like most people I
desire slow one step changes so that I might evaluate the benefits to my
family, myself and my business. The number of people using online email is
astronomical, it has been of a great service. The amount of electronic junk
mail I receive makes the paper mail coming thru my door slot look puny. I
think we will discover as many draw backs to this method of communication as
pluses. I also think that our government has no business involving itself in
the direction of the personal use of email.
Sandy Madison
Fort Worth, Texas
###
From: <webmaster@polly.mall-net.com>
To: NTIA.NTIAHQ(usdomain)
Date: 8/10/98 3:54am
Subject: USPS and internet
I think is pointless to "issue" an internet address to every
household. Who would use it? Most people do not have internet access,
and when they do get it, receive a service provider-specific e-mail
address. A non-service provider related address just means another large
translation table to translate and re-route e-mail messages sent to some
centralized location. As a webmaster and technology consultant, I can
tell you that this would be a stupid waste of computer power, internet
bandwidth, and disk space. It would become yet another franchise, like
the cable TV francise, that someone uses to milk the consumer. With the
current provider structure, they are all competing to give us the lowest
price.
Before doing anything else, extend anti-faxing laws to include
unsolicited commercial e-mail! (UCE, also commonly called SPAM.) The
number one threat to the internet, is saturation caused by unsolicited
commercial e-mail -- Spamming! When a person gets twenty spams a day, he
or she often starts looking to change their e-mail address or service
provider. Spam eats up connection time, people time, and disk space --
things we are PAYING for, not the sender of that crap! They are stealing
our time, our money, (as many still pay by the minute for time spent
downloading e-mail,) and our disk space! Make it a crime!!! The simplest
and cleanest solution is to take existing anti-junk-fax laws and say they
include unsolicited commercial e-mail messages.
Look at the way airlines were encouraged via subsidized air mail.
That is a good model.
1. Subsidize school and library access to the internet in every town.
If they get any Federal subsidies, they need to have their schedule and
card catalog on the web.
2. Requre every Federal Court place all public trial data on the web
using internet service providers in their locations, and allow as much as
possible to be done via the web, including the scheduling of appointments
and the payment of fines. Same for all Federal Law publications, and
eventually, all Federal Publications.
3. Require all Federally subsidized police departments to provide
public services via web pages and e-mail. That includes answering
questions, accepting complaints, and providing "solution" pages for common
local problems on the web. Crime statistics (incident counts by category)
on a per-block basis would be very nice too!
4. Require all subsidized Department of Transportation sites to
provide service access via web pages. That includes non-photo Driver's
license renewals, auto registrations, fine payments, etc.
3. Encourage states to place all their public records on the web;
everything from their laws, to town meetings and real-estate transaction
notices.
These will encourage the creation of local internet service providers
across the country.
The two major players will eventually be the telephone companies and
the cable TV companies. Our major fear is that neither will allow
individuals to serve their own web pages. Freedom of speech should
include the freedom to publish our own web pages from our own computers,
not to rely on extra cost sites elsewhere. When we provide the world with
what we know, we attract people who become friends. Friends help friends,
relieving the burdens of social services departments and other
governmental service departments. The web of information soon becomes a
web of people helping each other.