Having commented on this in I-Network and again on the UIXP list, I am not 
really willing to type another long e-mail so please pair with me as I cut and 
paste my comments from the previous discussion:


The document contains a glaring inaccuracy:

4.1     The Current .Ug management arrangement
In Uganda, .Ug is currently administered by a privately owned company, Computer 
Frontiers International. This includes the setting of the policies on .Ug as 
well as the day to day technical and administrative functions of a ccTLD 
registrar and sponsor. This arrangement emanates from a historical set of 
events in which the owners of the Computer Frontiers, worked very hard to shift 
the management of the .Ug from a volunteer manager (Mr. Randy Bush) located in 
United States of America. This had come into the responsibility of Mr. Randy 
Bush when he had previously volunteered to manage many countries’ domain names 
as at the time when the domain names were assigned; many countries (mainly on 
the African continent) were not ready to manage their own domain names.

>>
Having been an active part of the actual process of transition mentioned above 
I need to make some things very clear:

1. Randy Bush was NEVER the ccTLD "manager" in IANA terms. He was the TECH POC( 
Technical Point Of Contact). Even by then Charles Musisi was the listed ccTLD 
manager.
2. There was no hard work involved in the shifting. Randy voluntarily 
relinquished running the technical end of the .ug registry once it was clear 
that we could now setup and operate our own .ug name servers. Various ISPs then 
in operation volunteered to be secondary and we also got secondary from RIPE so 
we could have some stability in case there was a general outage in Uganda. It 
was at this point that I became the new TECH POC which role I still hold. Randy 
graciously for many years did the technical registration work for a number of 
ccTLDs but there was always a manager from the country in question handling the 
role of ccTLD manager. 
3. I actually remember articulating and answering most of these questions in a 
session with a Mr. Bugaba of UCC around 2002.


in another part of the document in question once again very lofty goals are 
stated which in my mind have nothing to do with the ccTLD management:>>


>>

5.2
POLICY OBJECTIVE
The policy hinges on the following objectives: 
i.      To effectively manage and operate the domain name
ii.     To Promote the utilisation of the .Ug name space 
iii.    To Promote growth and development of ICTs in rural and low income
areas 
iv.     To Facilitate articulation of the views of Uganda relating to internet 
use, at
both local and international fora 
v.      To promote access to the internet across all marginalised groups.


>>

I fail to see how iii, iv and v are covered by this proposed transition. Number 
iv in particular is just an issue of participation in forums like Afrinic, 
IETF, ICANN, etc all which do not require one to be a member of the management 
of the ccTLD. I have yet to see which marginalised groups will get access just 
because the ccTLD management has shifted. Access to the internet has nothing to 
do with the ccTLD. There are a lot of people actively using the internet in 
Uganda who don't even know a thing concerning the ccTLD.

I leave it to someone else here to figure out how number iii in particular can 
ever be relevant to this particular discussion.

I do find it amusing that the document specifically states that after a UCC 
survey was done, it was found that the majority of stake holders were 
satisified with the current management of the ccTLD with only 11/30 disagreeing 
then it goes to state why it should be changed. Since when did the views of the 
minority come to trump those of the majority?

Point iv of the roadmap specifically mandates that the ministry of ICT would 
then become the primary sponsor or to use IANA terms becomes the ccTLD manager 
while the created NGO is simply technical. Be very afraid! The ccTLD manager is 
the one who sets policy, arbitrates disputes and ultimately decides on 
registration issues. The suggested model means that regardless of the board of 
the organisation, etc, ultimate management would have shifted to the government 
of Uganda making one stake holder's interests loom over all the others. I 
wonder why all those cheering for this change are simply NOT seeing the danger 
inherent in this?

If this implication is not clear enough.. please note the following assertion 
at the end of the document:

"As ccTLDs become increasingly important, national governments are beginning to 
assert control over the administration of their ccTLDs. It is very ideal that 
Uganda joins the rest of the world and takes control of its ccTLD."

So this has nothing to do with all stakeholders having an equal say in the .ug 
ccTLD management. This is about government grabbing control forcefully of the 
ccTLD. The document actually explicitly states that The Minister responsible 
for ICT and the Executive Director of Uganda Communications Commission shall be 
the Trustees of ugNIC, on behalf of all the stakeholders. 

Be "very" afraid! The document states that explicitly:

"Administration of ccTLD within the country is vital because the regulation, 
renewal, suspension of domain names and the disputes that may arise under the 
ccTLD, will be governed by the Uganda laws."

Ask yourself whether a group like "activists for change" would remain with a 
domain name or even get to register one under this proposed management 
framework.


Noah.

On Jun 8, 2011, at 9:49 AM, Reinier Battenberg wrote:

> Hi,
> 
> It seems there is an attempt going on by the Ministry of ICT to form a new 
> body to manage the .ug tld. The document describing the reasoning behind this 
> you can download from here 
> 
> http://www.ict.go.ug/index.php?option=com_docman&task=doc_download&gid=54&Itemid=61
> 
> One of the steps in this whole process is gathering feedback from the 
> community, which so far has been done by meetings on invitation.
> 
> Maybe its a good idea to exchange some ideas around the concept here, too.
> 
> -- 
> rgds,
> 
> Reinier Battenberg
> Director
> Mountbatten Ltd.
> +256 758 801 749
> www.mountbatten.net
> 
> 
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