from the november 1997 cook report

Administration of .us Domain Gradually Changing

But Volunteer Effort Run with Good Intentions Fails to Be Fully Responsive
to Needs of Commercial Network


Editor's Note:  For a year or more we have been hearing complaints about
the state of the .us top level domain. We found time to have a look. This
article is a summary of what we found. We sent the draft to Jon Postel and
asked for comment. Jon and two of his delegatees replied. We have
interwoven their comments into our text, prefacing each paragraph with the
author's name.

COOK Report:  "Dot us" has for many years been managed by the IANA offices
at the Institute for Scientific Information of the University of Southern
California. Jon Postel, as IANA [Editor: In mail to us cited below, Jon
pointed out that in this capacity he is called the .US Domain
Administrator], has had a set of generally simple criteria where if someone
from the Internet 'community' came and for example said to him: I'd like to
be made responsible for all registrations in the portland.or.us domain, as
well as the 40 surrounding towns, that person would likely be given the
assignment. While the community was still small, the numbers involved were
small and could easily be done on a volunteer basis as a part of the
cooperative environment from which the network grew.

Jon Backstrom: This worked well for a long time and the best delegated
authorities are often the people who volunteered early.  The emergence of
people who saw US Domain registrations as a profit opportunity has changed
this a great deal, in my opinion.

COOK Report: As the internet grew, it gradually became acceptable for those
who were delegated, third level, city registration authority to charge a
small annual fee to cover their expenses in running local DNS servers and
related tasks. Things were done informally. An entry in a master data base
and a form filled out and that was it - be it registration services for
town of 10,000 or a city of more than a million. Some folk liked the role
and came back for more cities and towns often in states far removed from
their place of business. Other than the consensual trust by which the
internet had always operated, there was basically no oversight and quality
control. After the passage of a year or two a registrar sometimes would
move or get interested in other things. But as long as few registered in
the .us domain problems would sort themselves out. The long term problem
however was that this informal system has not been able to scale.

Postel: We don't see any reason or evidience that this doesn't scale.  This
does seem to have much better scaling properties that the COM domain
management.

COOK Report: During the past three years, as the Internet has exploded in
size, all of sudden a lot of folk are interested in registering in the .us
domain. They will find a 550 kilobyte listing of all US towns and cities by
state at http://www.isi.edu/in-notes/us-domain-delegated.txt. There they
may look up the cities under which they want to register and find either
the email address [EMAIL PROTECTED] or the address of the second level
registry to which their town or city has been assigned. On the basis of a
scan of the whole list, it looks as though 50 to 60% of the geographical
entities within the US had been assigned by IANA to a secondary registry.
Unfortunately, if one wants to register in a city that Jon has delegated
and the registrar has just gone out of business or, for some other reason,
does not answer the phone or email or has an inoperative web site, the
possibility of use of the .us domain is effectively foreclosed.

Postel:  Not true.  If some delegated domain manager is non-responsive we
can and have revoked the delegation and may eventually delegate the
locality to another manager.  We don't do this quickly or on the first
report of a problem, but if a track record of problems develop we will.
[Editor: by foreclosed we mean that most commercial users of the Internet
could not afford to wait say one to three months for problem resolution.
For example consider Jon Backstrom's comments of August 22: "I have my own
interesting experiences when I tested the concept of registering US domains
in various localities around the US.  I am still waiting for some
delegations to be granted over a year or two later, but ISI has been very
helpful in most cases.  There are lots of varied rules as each delegated
authority can make his/her own policies, as long as they are applied to
everyone.  Some insist you live in the city you are requesting a domain
for, others have a capricious tone in saying "yes or no" to domain
requests.I think there will need to be more measures from ISI to increase
the accountability of certain delegated authorities, but I have only found
four problematic localities out of 50+ major cities I have dealt with."]

COOK Report:  The informality of the .us system has created some strange
circumstances. For example, when we scanned the entire .us listing, we
noted that, while many New York cities are handled out of a Troy NY
registrar, New York City was delegated to an entity called Prairie Net. The
listings for both NEW-YORK.NY.US, and ATLANTA.GA.US tells would be
registrants to request addresses from [EMAIL PROTECTED]

Backstrom:  The people who make money on the US Domain probably wanted to
get these domains, but I happened to ask at the right time, I suppose. The
fact that *I* administer these domains is hopefully a *GOOD* thing for
these localities in the long run.  I perform my services at no cost and
everyone is treated fairly by our staff.  I also have professional ties to
these cities and travel to them often. The nyc.ny.us delegation is run by
psi.net and atl.ga.us was run at Emory University, if I understand
correctly.  I first tried to contact both of these organizations to "copy"
the existing zone records into the new domains (new-york.ny.us and
atlanta.ga.us), but neither organziation cooperated.  (They have their
nameservers set so you can't do an "ls -d locality.st.us" to check the
existing domains.)

COOK Report: Prairie.net is the domain name for a company called Silicon
Prairie Communications. Its web site proclaims: Silicon Prairie
Communications is concerned with helping to build local community networks
and an Internet presence for rural areas and small cities (those with
typically less than 30,000 residents). Unfortunately, there is very little
else on the site and nothing about how to register a new-york.ny.us
internet address let alone one for Atlanta.

Backstrom: Our website is not up-to-date...true enough...and I guess I will
fix all that post-haste.

To Be Concluded in
December COOK Report

with no room in the december issue I published the conclusion in the jan 98
issue


A Look at the State of the .us Domain

Editor's Note:  We completed our writing of this article in August.
Unfortunately we had no space for it in our October issue.  We published
the first 25% or so of the article on page 22 of our November issue.  We
conclude the article here.  It is quite likely that, if we started over, we
would find the some of the deficiencies of the web sites about which we
have complained have been fixed.  We would certainly hope so.  But, given
what we have to do to keep abreast of the state of change in the rest of
the internet, we shall not throw this material out and start over.  It was
accurate in August and we are confident that the general situation still
holds as we go to press in early December. Namely that.us has not scaled in
sync with the needs of the commercial Internet. Jon Postel complained to us
about our statement.

We respond that while in terms of the ability to put out large quantities
of addresses .us scales fine, in the sense of being ready for someone to
easily and conveniently use for electronic commerce it  does not scale.  In
this sense scaling means the presence of the kind of straightforward
process of register by web and have the domain active within a day of two
that Network Solutions gives for dot com is simply not available for .us.
Because of this serious business use of the net will continue to gravitate
to .com.  We wish it were otherwise.  But the seat-of-the-pants operation
of .us described here is simply inappropriate for the commercialized
mission critical Internet.

[cont'd from p.22 November 97 COOK Report] Backstrom: In the past two
months (because of the situation with Iowa State), I have had to consider
how to be a lot more serious about our image, since I'm not affiliated with
the university anymore. I am waiting for a permanent T1 connection to be
installed and set of new Class C assignments.  Once my new installation
completed, I will address this particular issue and install a re-vamped
(professional) web site.  Right now, I consider myself a start-up.  You can
see our other work at Infoplex Communications (http://www.infoplex.com).

COOK Report: Two of the largest cities in the U.S. have what looks to be a
rural ISP as their registrar. A whois showed:  Silicon Prairie
Communications  P.O. Box 555 Indianola, IA 50125-0375. A call at shortly
after 6 pm on Friday August 15 yielded their answering machine.

Backstrom: I'm proud that I can provide DNS services for two of the largest
cities in the U.S.  I should point out that I do a competent job and the
services have been free of charge to all concerned.  I also provide the
same excellent service for Kansas City, Omaha, Des Moines, and Portland,
Oregon.

COOK Report: We have talked to an Atlanta area ISP who said that folk
wanting Atlanta addresses found themselves essentially out of luck. He
added that an attempt to register atl.ga.us had been turned down by Jon
Postel in his IANA [.us Domain Adminstrator] capacity. It certainly seems
that an inordinate amount of power has been turned over to people with no
accountability for its use.

Backstrom:  I'm concerned about this statement, since this it implies I'm
not doing my job.  In the past month I have registered several Atlanta
domains and made nameserver modifications to three existing domains. If
they want an atl.ga.us, it's true...you are out of luck as the new ISI
policy moves people to atlanta.ga.us.  But registrations are happening all
this time under this new name. From mid-June to mid-July all registrations
were on hold because of the actions of Iowa State University, but once the
nameserver was re-established on a private network, I was able to quickly
complete all pending requests.  (This is not too far from the situation I
had with sesqui.net...the Texas organization that requires a long wait to
process requests.  I waited 5 weeks to establish a domain under
dallas.tx.us and I had to wait 6 weeks with oar.net in Ohio to get a domain
under cincinnati.oh.us)

COOK Report: We made a list of nine other registrars who had been granted
DNS delegation rights for at lease a few dozen cities often in multiple
states. When we went looking for web page instructions, we found the
following. Only one of the nine had an informative working web site. This
was [EMAIL PROTECTED] Nametamer proudly proclaims that they will
assign names if you live in one of THEIR cities for only 34.95 a year. The
next [EMAIL PROTECTED] had no web site that we could find. The web site of
[EMAIL PROTECTED] was being redesigned and we could get to no data.
Then at [EMAIL PROTECTED] we found a web site but nothing about city
level names under the .us domain. Domainregistry.net appears to have no web
site. [EMAIL PROTECTED] is situated in nevada, but if it were
possible to register reno.nv.us with them we were unable to find out how.

The next business [EMAIL PROTECTED] administers most of Connecticut
and much of NY as well as NJ. The web page came up and the link that
describes how to register domains didn't work. (We made two attempts on
this one five days apart.) Then there was [EMAIL PROTECTED] which handles
Delaware and Maine but had a web site with no data. [EMAIL PROTECTED]
registers much of Massachusetts but with no web page data. Our small
informal survey showed a situation that was not exactly consumer friendly.
No wonder that others had said to us that .us was so badly messed up as to
be basically unusable.

Backstrom: I would disagree and I think this is a matter of understanding
the best path to establish a domain...the US Domain template has *ONE*
submission [EMAIL PROTECTED]  The submitted template is then
automatically forwarded to the registrar of the domain for processing.
>From there, individual differences show up.  Some registrars are slow, some
charge fees, some are difficult to deal with.  This *IS* problematic, but
there is also an official "jumping off point".  It's not "unusable"...

COOK Report: Recently Jon seems to have revised the criteria for delegation
as a registrar in .us. The .us domain pages indicate that the site had a
major revision on July 22. On July 1 Jon announced that he would in the
future assume that any registrar for a city had the approval of the local
government and that should the government contest the rights of the
registrar it would award them to the government. Definitely a step in the
right direction, but one that may not do New York City or Atlanta any good.

Backstrom:  My concern about this new policy is that people who want to
profit from the US Domain might influence a city government to grant
him/her the "preference" to become the registrar.  This might lead to a
situation where the brother of a city-official might want to become the
delegated authority for the sole purpose of a local franchise (for monetary
gain).  Once the city says "OK...you can be the delegated authority for our
locality", what happens if they change their minds? Should an ISP get
approval once, is that enough for all time?  What if the city wants to move
the delegation from a competent ISP based on a whim or pressure from their
own ISP who might want to control it? A lot of US Domain people are
offering e-mail forwarding (like the services offered by netaddress.usa.net
or iname.com) in the locality they control.  If the delegated authority
changes, these services are possibly put at risk for the people who depend
on them...unless the MX records for the domain remain assigned to the
original ISP.  The whole situation of "who should control the local domain"
has been made much more complicated by services like these.

COOK Report: Jon certainly did not set out to make to make the .us domain
unusable. We are sure that he acted with the best of intentions, but by the
time he realized that, in yet one more area, the commercial internet had
brought him new headaches, it was essentially too late.

The current criteria for becoming a registry are listed at
http://www.isi.edu/in-notes/usdnr/usdom-overview.html. For our reader's
convenience the first half follow.

Delegation

Most branches of the US Domain are delegated. Typical delegations are
localities (cities or counties), companies within cities, k12 schools,
community colleges, libraries, state and federal government agencies.
Examples of delegations are K12.TX.US for K through 12th grade public
schools, in Texas, a locality "BERKELEY.CA.US", or LIB.MN.US for the
libraries in Minnesota. There must be a knowledgeable and competent
technical contact, familiar with the Internet Domain Name System. We do not
provide technical support. We only register the domain names.

Organizations requesting delegations must provide at least two independent
(robust and reliable) DNS name servers in physically separate locations on
the Internet. The servers should be active and responsive to DNS queries
BEFORE the application is submitted. Incomplete information about the
servers and IP addresses or inactive servers will result in delay of the
registration. The subdomain administrator must accept all applicants on an
equal basis and provide timely processing of requests. The subdomain
manager must notify the US Domain Registrar immediately about any changes
in the name servers that should be reflected in the US Domain zone files,
or changes in the administrative and technical contact information.
Administrators must follow the guidelines in the current US Domain RFC and
assist applicants in selecting a domain name.

The contact phone number given to US Domain Registrar should be answered
during the business hours. All messages received after business hours
should be answered the next working day. This is required to resolve
problems either by US Domain or by the customer directly. If we receive
many complaints or experince any problems ourselves in getting touch with
the delegated manager the delegation may be revoked.

Some domain managers have taken on the responsibility for managing a large
number of locality domains. To promote diversity, no single domain manager
(person or company) should be responsible for more than 50 localities in
one state, or 500 localities in total.  For delegations (or redelegations)
made after 1-Jul-97, it is assumed by the US Domain Administrator that
every applicant for the delegation (or redelegation) of a locality name has
the written agreement of the legitimate government for that locality for
the applicant to manage the domain name of that locality.

Readers will find the remainder of the criteria at the above listed URL.

Jon Announces the Probability of Charging and Provides a FAQ for Registrars

On Friday Friday, June 20, 1997 the following post was made to us-dom
[EMAIL PROTECTED] mail list.

We appreciate the service you are providing by supporting the subdomains of
the US Domain. Our service of managing the overall structure of the US
Domain has been paid for under the terms of a Cooperative Agreement with
the National Science Foundation (NSF).  Specifically, Network Solutions
(NSI) has a Cooperative Agreement with NSF to provide registrations
services.  At the time this agreement was established it was explicitly
understood that NSI would subcontract to ISI to manage the US Domain.  NSI
has provided these funds.  This agreement will end in March 1998. Starting
in the spring of 1998 our service must become self supporting.

We expect to introduce an annual charge for maintaining the records of the
subdomains we delegate.  The charging would start in spring of 1998. At
this time -- and subject to change -- our estimate is that the charge per
delegated subdomain will be about $30 per year. We will consider other
alternatives for funding our work.  Perhaps such charging won't be
necessary.  However, this constitutes a notice that charging could begin in
spring 1998. Please let us know your comments soon. Thanks, jon & shanthi

[Editor's Note: on Friday August 15 we succeded in reaching Shanthi by
telephone. Unfortunately, when we told her that we were "press," she
informed us that she could not answer our questions and that only Jon could
do so. We then told her we would send Jon the draft of this article for
comment. The June 20th message concluded with a list of Questions and
Anwers]

Q.1.  How much profit with the US Domain be making ?

[It is a] not-for-profit service.  The US Domain is an activity of ISI
which is part of USC.  The University is very good at keeping separate
accounts for separate activities and making sure that all the costs and
income for each activity are charged and  credited to the proper accounts.
The US Domain activity is a "cost center" which means that any excess or
loss in one year has to be taken into account in the budget planned for the
next  year.  The fees could be adjusted up or down in subsequent years to
bring the budget into balance.

Q.2.  Can ISI provide a breakdown of the costs?

A.2.  The current budget distribution is shown below.  This would change in
the future to include accounting and billing functions.

Budget Category         Percent
Salaries+Benefits       55.7
Supplies         0.1
Travel  1.4
Computer+Network        10.9
Overhead         31.9
-----------------------------------
Total   100.0

Overhead includes rent, power, air conditioning, furniture, library access,
financial oversight, insurance, and many other services. If there are legal
cost to pay for they will be much larger than the cost of operation the US
Domain.

Q.3.  What about other ways of funding this?

A.3.  If we can find a different way of funding the operation, we would be
happy not to charge fees to the delegated managers. It would be a lot
easier to get a few large contributions rather than collect thousands of
small fees.

Q.4.  Why does it cost so much?  Can't it be dome with an automated mail
processing script?

A.4.  Yes, much can be done with scripts and automated processing. The cost
are in handling the exceptions, dealing with people that don't understand,
and complaints about delegated managers that don't respond.

Q.5.  What "delegated subdomains" will have to pay?

A.5.  All subdomains listed with NS records in our zone files will have
TEC, CC, LIB, MUS, GEN, STATE, COG, DST).  Also any direct registrations
with us that have A or MX records in our files will have to pay.
Q.6.  Why not just charge the managers that charge their customers, and not
charge the managers that do the work for free?

A.6.  We would have to keep track of this, and we would have to deal with
managers that change from one case to the other.  We would need to rely on
you to keep each other honest.  One concern is that the charge would have
to be higher if fewer are paying, and this could spiral into the ground if
the managers that charge start going out of business.  And for those
figuring out what the income would be at $30 times the number of localities
now delegated try guessing how many would be given back rather than being
paid for.  We are also concerned that this may violate the equally.

Q.7.  Why not delegate all the state codes out and significantly reduce the
work done at ISI?

A.7.  We are considering this.  We would consider delegating a 2nd level
state code to a state agency or a large long established non-profit
institution or a university in the state.  If there are multiple requests
for such a delegation we would respect the wishes of the Governor's office.

Q.8.  Is it ok for a 3rd level locality name to be delegated to someone not
in the locality, or not even in the state?

A.8.  Currently yes.  We are thinking of a new rule to require the person
requesting a locality delegation to have a letter from the locality
government authorizing him to manage that locality. We really don't want to
have to do any checking of credentials of the applicants for domain
delegations -- it takes time and increases costs.  Another idea we are
considering is to have 3rd level codes like CI and CO in each state and
delegate them to a state with the conditions that only locality names cam
be registered under them and only when the request is from the authorized
representative of the locality government.

Q.9.  Is it ok for one delegated manager to hold thousands of delegations?

A.9   No. The 50/500 rule applies.  No one manager is to have more that 50
delegated 3rd level names in a state or more than 500 delegated 3rd level
names in the US Domain in total.  There are a few domain managers that have
more than would be allowed by the 50/500 rule, these managers received
these allocations before the rule was established.

Q.10. Is it ok for managers of 3rd level names to charge for 4th level
delegations that were registered before the 3rd level was delegated?

A.10 Yes, but only after notifying the manager of the 4th level name a year
before the charging begins.

Q.11. Should the RFC describing the US Domain be updated?
A.11.  Of course.  Right after we do all the other things.

Q.12.  Should ISI be replaced as US Domain manager?

A.12. Quite possibly.  We don't seem to get anything out of this butgrief.
And there are interested parties in the US Government that may want input
into how the US Domain is managed.  Maybe they will choose someone else to
do the job.

Q.13. Should someone start a new "US" domain with the TLD code "USA" (or
something else).

A.13. Sure that would be fine with ISI.  Please follow the IAHC process.

General Comments on Article from IANA,
Michael Bathrick and Jon Backstrom

Postel: August 21:  I think your suggestions about the us domain delegation
plan not scaling and having non-recoverable dead delegations are off base,
and not supported by any facts in your report.

It is true that the requirements on the delegated domain managers are less
exacting that perhaps are necessary for commercial service providers,
though this may change over the course of time.

You could note that according to the Lottor survey the US domain (for all
its supposed problems) is the 9th largest top level domain and the 5th
largest of the country code domains.

We make a distinction between the IANA work and the US Domain work. Maybe
this is a too fine splitting of academic hairs for most people to grasp.
We have a US Domain Administrator at ISI that manages the US domain.  This
is separate from the IANA.

On August 22 Michael Bathrick wrote:  There never was a requirement that I
place information on my web site for info on how to subscribe - that info
resides on ISI's website.  Those folks who *have* placed this info on their
home pages have often been accused of doing it for profit. I'm not in this
for profit, I'm nothing more than a grunt here doing the work for free.

I always answer my email regarding .US delegations, and if the forms are
filled out properly, I delegate these domains within 1 working day.  Pretty
good, since since I *don't* charge $50/year, 2 years in advance...

The big dispute in the .US domin is not how easy/difficult it is to
register - for the most part it is the great variance in pricing for the
service.  I, for one, have been doing this in the spirit of the internet.
This may have to change if the proposed $40/year fees from ISI become
reality, but until then I will continue to do this for free.
Also on August 22 Jon W. Backstrom wrote to us: To start with, I consider
myself one of the "good guys" in the US Domain infrastructure.  I have
worked hard to manage several large US delegations and I also do a fair
share of the state of Iowa.  For all my work on behalf of the US Domain, I
have never charged anyone a dime for my services.

My prime concern has always been to keep things free (or very low in cost)
in the traditional sense of the US Domain and I have tried to be very
service-oriented.  This goal has been tested during June and July of this
year because of events I could not control, however.

As an employee of Iowa State University, I managed all my US domains as
part of my job (and the responsibility moved with me as I changed positions
from department to department).  When I left the university to work at
Meredith Corporation, the primary US Domain nameserver for my delegations
was abruptly pulled off the network without regard for the consequences.
(The Agronomy department did not adhere to their agreement to keep the
server running while it moved to a new place on the net...and they had no
understanding why it was important.)

Consequently, I was left keeping the domains working by converting one of
the secondaries (on a distant network) to the role of primary until the new
nameserver could be established.  I worked hard to get a network installed
(the phone company didn't install for a month), and I finally managed to
get things back to normal after a month of time where new delegations were
"on hold".

There is a basic thread of truth in your article and you are right to be
concerned about the state of the US Domain, but you seem to mention
atlanta.ga.us, and new-york.ny.us in your article.  All of these are my
delegations...and just want you to understand that I try to do a good job
and the fact that all of these cities are being serviced by "rural ISP in
Iowa" doesn't mean that people aren't able to register and use these
domains.  In fact, I offer a lot of help and guidance to people who write
to me about "what to do to get a domain".

The biggest news about my own situation is that I'm going to start a new
service policy...allowing "one domain registration for free" with
additional domains for organizations being invoiced at $10/yr.

This will allow me to continue offering free domain registration while
collecting fees from those who want to register multiple domains under a
particular locality.  (Some people have over 10).  This would seem to be
the best way to insure the viability of my work on behalf of the domains.
I'll update this information on the web site and unveil a new set of pages
by September 1st.  (Multiple domain fees will start in 1998.)

***************************************************************************
The COOK Report on Internet      431 Greenway Ave, Ewing, NJ 08618 USA
(609) 882-2572 (phone & fax) [EMAIL PROTECTED] http://www.cookreport.com

NOTE: Contempt in which ICANN PRES. MIKE ROBERTS holds rest of Internet:
"Some of those people think the management [ICANN] should check with the
public [the Communities of the Internet] every time they make a decision,
which is crazy," Roberts said. "That's flat-out crazy." WIRED NEWS 2/4/99
***************************************************************************

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