Entries tagged with “iedr” from Domains / Internet Technology News - DNS News

Remember Comreg?

Remember the famous IEDR report?

It's now the 18th of December, which means that civil servants will soon be shutting up shop until the New Year.

And still we have no inkling as to the outcome of Comreg's investigations into the IE Domain Registry, the company currently charged with managing the Irish ccTLD.

Over 12 months ago the external consultants presented their report to Comreg and in turn this was shared with the registry. Unfortunately, citing concerns with privacy, security and business information, Comreg did not deem it necessary to share that report either with the public or stakeholders.

Months passed and then in June of this year Comreg finally opened up their consultation with the public.

That consultation period closed back at the beginning of August, but they are yet to actually publish anything.

How long does it take to put together a report?

Until such time as Comreg actually publish their report both the IEDR and stakeholders alike are going to be left in Limbo.

I've written extensively about the IE namespace and its current registry operator - IEDR in the past. While I've always tried to be fair and balanced in my coverage of the issues facing the IE namespace I'm afraid my patience with the current registry operator has worn thin.

While things may have improved over the course of the last few years it is becoming abundantly clear that the current registry operator is probably not the best organisation to manage the ccTLD in the future.

Comreg (the Irish Communications regulator) organised external consultants to conduct a comprehensive review of the IEDR's operations at every level. Although the report was submitted to Comreg before Christmas 2007 it still has not been published and is unlikely to see the light of day at this juncture.

More recently Comreg requested feedback based on the unpublished report's points (the logic behind this kind of thing escapes mere mortals, so you're not alone if you thought that was a weird thing to do!), yet nothing has been published.

Of course Comreg's track record in terms or regulating the various industries within its remit hasn't exactly been stellar, so maybe we shouldn't be so surprised.

So what is the current situation in IE?

If you were to rely on their annual report for that kind of information you'd probably end up with a rather twisted version of events.

At present there is no policy development process within IE.

While policy can change there is no clear way for stakeholders to propose changes or follow their development.

If a policy proposal is made and in many cases this appears to be provoked by something "upsetting" the registry operator, then the IEDR may pay lip service to consulting stakeholders. However consultation in their eyes and consultation for everyone else are often at odds with each other.

One recent change that has had a very negative impact on stakeholders was the registry's unilateral decision to practically do away with "conditional acceptances". That a domain could be "provisionally accepted" in the first place is a reflection of the archaic and unwieldy rules and procedures in place.

If you query how things operate you are most likely to get a rather inane response about how things have always been that way or that nobody "considered" a particular issue to be important enough to deal with.

Most of the ccTLD's registration rules are ambigous and open to subjectivity.

Since the "awarding" of a domain name relies almost entirely on the registry's staff subjective interpretation of the policies the end result is that prospective registrants and registrars are constantly locked in an unending game of "Russian roulette", though in many respects it's even worse, as you don't know how many chambers have been loaded.

In this kind of environment, with vague rules and no policy development, the incumbent registry operator now wants to introduce even more bureaucracy.

According to a small note in their most recent newsletter they intend to introduce an "appeals process":
The IEDR will shortly begin a consultation with the local internet community on the formation of a formal appeals process.

This formal appeals process would allow persons to:
a) appeal the IEDR's decision to reject an application for a new .ie domain name
b) appeal an already registered domain name
c) appeal the suspension or deletion of a .ie domain name

We will be circulating a consultation document for your consideration over the coming days

Eventually the IEDR provided more information on their proposal:


The IEDR would like to receive your views on the formation of a formal appeals process.
This formal appeals process would allow persons to:
a) appeal the IEDR's decision to reject an application for a new .ie domain name
b) appeal an already registered domain name
c) appeal the suspension or deletion of a .ie domain name

We would like to suggest adopting a two stage approach to the process. The purpose of this
approach is to reduce the number of inquiries escalated to a formal appeal and minimise the costs incurred by the appellant and/or the registry. The first stage of this approach would involve the IEDR being given the opportunity to review the appeal internally and respond. Our aim is to address the appellants' issue wherever possible at this stage, however if this is not possible or the appellant remains dissatisfied with our response they could then choose to initiate the second stage of process by opening a formal appeal which would be brought before an expert/panel of experts for a decision.

Currently, the IEDR receive very few appeals and do not feel that the introduction of a formal
process should increase the number received in any way (see (1) below). The purpose of this
consultation is to ensure that the formal process is structured to reflect the needs and
considerations of the local internet community.

While the idea behind this is obviously inspired by the Nominet DRS and similar solutions there is no way to easily transplant that kinf of sytem into the IE namespace. Other ccTLDs are much more member-driven ie. the stakeholders have some say in how the organisation is developed and run (AFNIC, Nominet, DENIC etc.,) while IEDR is a private company with zero accountability. The lack of clear and unambiguous rules and processes mean that both registrants (end users) and companies fulfilling the registrar role (there is no such role currently defined) face a very high degree of uncertainty. If any appeals process were to be introduced it would be a fiasco.

Fundamentally the IE namespace is in serious trouble.

The  organisation currently in charge of managing the namespace may have muddled along for the last few years, but it is showing itself to be severely lacking on both technical and non-technical aspects of the ccTLD's management.

The archaic rules and procedures are stifling development not only of the namespace but of online business in Ireland.

This morning, for example, all public facing web services related to the IE namespace were completely unavailable for a period of approximately two hours. During this period whois, the API and all other web services were completely unavailable.

At no time did the registry make any effort to contact its registrars to explain the downtime and when an "explanation" was finally provided it was incredibly vague and unhelpful. A gTLD registry operator has to meet SLA requirements. Why doesn't this kind of thing exist for a ccTLD?

For a ccTLD registry in a developed country this kind of technical ineptitude is worrying.

So what could, or should, be done?

The main area of contention is in regard to the rules and regulations. At present those rules and regulations are not helping anyone, least of all the user community that the ccTLD is meant to serve. It would make a lot more sense to do away with all registration restrictions apart from maybe an admin contact address restriction.

The IEDR has long argued that its position as a "managed" registry gave it certain advantages, however most registrants do not gain any tangible benefits from these supposed advantages.

With simpler rules there would be less manual intervention required by both the registry operator and the registrars which would improve the turnaround time on new registrations and also help reduce the cost to end users significantly (the average cost at present is approx 25-30 euro before sales tax). The cost that end users pay for a domain registration will always be affected by the amount of manual intervention (if any) that the registrar's staff has to make to get a domain registered and / or manage it on an ongoing basis.

The other area that needs to be addressed urgently is the total lack of properly defined relations between the registry, registrar and registrant. At present there are no official "registrars", as the IEDR has not drafted any form of registrar contract. This puts all three sides in a legal minefield and issues can and will arise, although querying this sort of legal issue with the registry will not get a favourable response.

Maybe things will change dramatically if and when Comreg publish their report, however if they don't then maybe it is time that the management of the registry be put up for public tender or simply redelegated entirely.

The IEDR, which is in charge of the IE namespace, is looking for staff.

The position on offer is "team leader" in "registration services"

Full details are available from David Curtin, IEDR's CEO (david.curtin at iedr.ie)

David Curtin, IEDR CEO, was interviewed during the week by Sunday Business Post's technology editor Adrian Weckler

The full interview is available online.

Some of the questions posed by Weckler revealed some of the more awkward and restrictive views of the registry, including its policy on censoring domain names.

However it is interesting to note that Curtin not only made public reference to setting up a policy advisory board, but also mentioned the registry's plans to introduce support for IDN's (finally!).

Some of the answers, however, are amusing.

Curtin seems to believe that people register larger volumes of domains in .com as they are afraid of "cybersquatting".

While this may be true of large corporates it is most definitely not the case with Irish SMEs. Most Irish SME users register theircompanyname.com and possibly theircompanyname.ie. They won't register derivatives or typos unless someone tells them to.

The fact that so many people still opt for a .com over a .ie cannot be explained away by referring to Curtin's favourite bogeyman dotCom (he's taken to referring to them as a competitor).

Basic fact:
IE domains cost at least two, if not three to four times, more to register than a .com.
The average cost of registering an IE domain is approximately 40 euro per annum, if you average the price across the largest vendors.
The average cost of registering a .com domain is approximately 8 euro.

The cost of registering a domain name is directly related to the level of automation possible. Since IEDR's systems still rely heavily on human intervention both at the registry and registrar (reseller) level real competition with doteu and dotcom is not a viable proposition at this juncture.

An average SME that does not conduct a large portion of its business online may want email and an online presence, but probably won't want to spend more on the domain than they have to.

The supposed added value of a dotIE is primarily of interest to large corporates. Smaller business is not as concerned with trademark issues as some people would like to make out.

If the registry wanted to seriously increase the number of IE registrations they need to invest some of their surplus in marketing, PR and possibly co-marketing with their stakeholders.

The IEDR's annual report for 2007 has been published (
IEDRAnnualReport2007.pdf )

Of course they didn't bother telling any of their stakeholders that it had been released, but we're more or less used to their lack of communication at this stage, as they prefer to tell the media!

In any case with the current Comreg public consultation ongoing the report was bound to make at least a passing reference to the regulatory changes.

The introductory section did not disappoint:

As a result of the Communications Regulation (Amendment) Act 2007, regulation of the .ie namespace passes from the Minister for Communications, Energy and Natural Resources to ComReg, which is empowered, subject to consultation with the relevant Ministers and the approval of the Oireachtas, to issue regulations over a range of operational and other matters in relation to .ie.

It then continues:

Our international competitors, .com and .eu etc., are not subject to the Act or to ComReg regulation. So we have a concern, which we expect ComReg would share, that the impact of regulation should not militate against the continued growth and development of .ie.

They conveniently ignore that .eu is answerable to the European Union, which is a lot more onerous than any national body.

Other parts of the report deal with the company's retained profits. Similar to Nominet and other ccTLD registries the IE Domain Registry does not have any financial issues.

It's unfortunate that the bulk of the annual report was drafted prior to the recent ICANN meeting, as it would have been interesting to see what kind of comment they'd have made on the new TLDs.

When it comes down to the actual figures involved there are few surprises, though how the figures are framed is questionable at times. The reliance on webhosting.info's statistics, for example, is quite disappointing. The assumptions about registrant density are also quite odd, as only a portion of a ccTLD's registrants would actually reside in that country. This is of particular importance if you wish to examine the registrant makeup in *.uk for example, which has a very open registration policy. It would have been a lot more interesting to see a report similar to that produced by AFNIC last year.

The cost of IE domains to resellers has been dropping, but sales figures and turnover has been increasing.

Of course the report doesn't make it clear that not all resellers will pass on savings to users, so certain assumptions and gaps in the report may lead readers to get a slightly different persective.

The introduction of "personal" IE domains gave a boost to registration figures for 2007. That's hardly surprising really.

But what about the antiquated and ambiguous policies that the registry still enforces?

The IEDR's David Curtin is a stalwart defender of some of their views, which seem to be at odds to those of other ccTLD managers.

For example the lack of a formal aftermarket in IE domains would be seen as quite negative by many industry observers, whereas Curtin seems to view this in a positive, yet incredibly naive and misinformed light:

...there is no formal secondary market for .ie domains, therefore the problem of
poaching of domains and holding them to ransom is not an issue...

A healthy secondary market does not have to involve "poaching" of domain names and I'm amazed that a man of his intelligence would make such a comment. That's almost like saying that selling property to the highest bidder should be illegal.

One of the "unique selling points" of the IE namespace is its supposedly higher level of security:

Other countries that made different choices regarding the type of ccTLD Registry
are now facing the challenges of costly intellectual property disputes, identity theft, phishing, cybercrime and credit card fraud.

It will be interesting to see if any of the media do more than simply recycle the press release.

Update: Now linking to a local copy of the IEDR's report as the link on their site seems to have been removed