5th June 2019
The Chair of the Nominet Board today posted the following response on the Nominet Forum:
I am writing in response to the recent open letter to the Nominet Board signed by a number of registrars and stakeholders.
Firstly, I would like to assure you that whilst the Board is not involved in the day-to-day operations and decisions, naturally we have received regular briefings from the executive throughout the duration of the rights reservation period.
In the past 12 months particularly in the approach to the end of the five-year period, these have become more detailed and frequent, including a full briefing on the finalised release process at our meeting two weeks ago.
The signatories raise a number of points about the registration process for domains which have been reserved but will become available for registration in July. The 2013 decision by the Nominet Board was that these should be allowed to be registered on a first-come, first served basis. As our priority is to ensure an orderly conclusion to the right of registration period, rather than to maximise revenues, we saw no compelling reason for change.
The key challenge for Nominet is to ensure the integrity and resilience of our registration systems, both for these names and for names registered in the normal course of business. This has resulted in two key features closely related to the matters you have raised.
Firstly, we are using a separate system and a specific release process for these domains. This is due to the likely volume of domains being made generally available for the first time and a requirement to keep registration entirely segregated from our usual registrations. Secondly, in order to prevent system overload by users seeking to register very many names simultaneously, we are limiting registration requests to a prudently low number per minute.
I have put your detailed questions regarding the release process to my executive colleagues who have replied as follows (using your numbering):
1. The sign-up period. We believe that we provided a clear and adequate period of time for participation, including notifying all registrars through the usual channels. Members who attended the recent Annual Conference will recall specific reminders to sign up to the release and no issues at all were raised by those present about this being difficult or unreasonable. With only a finite number of connections available, it would be unfair to change the approach to the detriment of those who had signed up in time.
2. Allocation of registration requests. There are obviously a number of ways in which this could be approached, as was discussed in some detail during the member webinar. However, we decided that registration requests would be allocated most fairly in relation to the total number of domains that a registrar was aiming to register. This was based wholly on each registrar’s own assessment of volumes. The funds or credit limits are designed to ensure that successful registrations can be paid for, and to avoid gaming of the system. We recognise that the tiering system we have adopted creates some significant ‘jumps’ in funds required. Those worried about financial capacity to register the numbers they indicated can either seek an increase in credit limit based on the usual principles, or place money on account. This is a reasonable, and non-discriminatory method by which to allocate a limited resource. The final allocations per minute will confirmed at the end of June, dependent on the final number of qualifying registrars in each tier.
3. Access to systems. You ask that WDM and EPP codes may be made available. It has not been our approach to provide or write code for registrars, and we have taken the decision to adopt a conservative approach using one system to maximise resiliency for this short period of heightened demand. We do appreciate that some registrars may be unfamiliar with our main EPP system; they have the option of using publicly available code, or could work through another registrar.
4. Contacting registrants. We emailed registrants at the start of the process, and have subsequently worked with registrars to raise awareness of the issue. As existing third level registrations will of course continue to function as normal, our intention here is not to bombard people or scare or pressure them into registering. That said, where we are not confident that registrars have informed their customers, or for those who have registered directly with us, we will shortly be sending a communication via email or direct mail.
5. Awareness-raising. Members will hopefully be reassured to hear that the awareness campaign we briefed members on at the recent Annual Conference and webinar is underway.
I would stress that the Board has taken the points raised very seriously and there has been extensive discussion about our response. While I am well aware that this may not be the desired outcome for all registrars, the Board is confident that the approach we have adopted is sensible and pragmatic.