Network Working Group J. Klensin
Request for Comments: 3071 February 2001
Category: Informational
Reflections on the DNS, RFC 1591, and Categories of Domains
Status of this Memo
This memo provides information for the Internet community. It does
not specify an Internet standard of any kind. Distribution of this
memo is unlimited.
Copyright Notice
Copyright (C) The Internet Society (2001). All Rights Reserved.
Abstract
RFC 1591, "Domain Name System Structure and Delegation", laid out the
basic administrative design and principles for the allocation and
administration of domains, from the top level down. It was written
before the introduction of the world wide web (WWW) and rapid growth
of the Internet put significant market, social, and political
pressure on domain name allocations. In recent years, 1591 has been
cited by all sides in various debates, and attempts have been made by
various bodies to update it or adjust its provisions, sometimes under
pressures that have arguably produced policies that are less well
thought out than the original. Some of those efforts have begun from
misconceptions about the provisions of 1591 or the motivation for
those provisions. The current directions of the Internet Corporation
for Assigned Names and Numbers (ICANN) and other groups who now
determine the Domain Name System (DNS) policy directions appear to be
drifting away from the policies and philosophy of 1591. This
document is being published primarily for historical context and
comparative purposes, essentially to document some thoughts about how
1591 might have been interpreted and adjusted by the Internet
Assigned Numbers Authority (IANA) and ICANN to better reflect today's
world while retaining characteristics and policies that have proven
to be effective in supporting Internet growth and stability. An
earlier variation of this memo was submitted to ICANN as a comment on
its evolving Top-level Domain (TLD) policies.
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1. Introduction
RFC 1591 [1] has been heavily discussed and referenced in the last
year or two, especially in discussions within ICANN and its
predecessors about the creation, delegation, and management of top-
level domains. In particular, the ICANN Domain Name Supporting
Organization (DNSO), and especially its ccTLD constituency, have been
the home of many discussions in which 1591 and interpretations of it
have been cited in support of a variety of sometimes-contradictory
positions. During that period, other discussions have gone on to try
to reconstruct the thinking that went into RFC 1591. Those in turn
have led me and others to muse on how that original thinking might
relate to some of the issues being raised. 1591 is, I believe, one
of Jon Postel's masterpieces, drawing together very different
philosophies (e.g., his traditional view that people are basically
reasonable and will do the right thing if told what it is with some
stronger mechanisms when that model is not successful) into a single
whole.
RFC 1591 was written in the context of the assumption that what it
described as generic TLDs would be bound to policies and categories
of registration (see the "This domain is intended..." text in
section 2) while ccTLDs were expected to be used primarily to support
users and uses within and for a country and its residents. The
notion that different domains would be run in different ways --albeit
within the broad contexts of "public service on behalf of the
Internet community" and "trustee... for the global Internet
community"-- was considered a design feature and a safeguard against
a variety of potential abuses. Obviously the world has changed in
many ways in the seven or eight years since 1591 was written. In
particular, the Internet has become more heavily used and, because
the design of the world wide web has put domain names in front of
users, top-level domain names and registrations in them have been
heavily in demand: not only has the number of hosts increased
dramatically during that time, but the ratio between registered
domain names and physical hosts has increased very significantly.
The issues 1591 attempted to address when it was written and those we
face today have not changed significantly in principle. But one
alternative to present trends would be to take a step back to refine
it into a model that can function effectively today. Therefore, it
may be useful to try to reconstruct 1591's principles and think about
their applicability today as a model that could continue to be
applied: not because it is historically significant, but because many
of its elements have proven to work reasonably well, even in
difficult situations. In particular, for many domains (some in
1591's "generic" list and others in its "country code" category) the
notion of "public service" --expected then to imply being carried out
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at no or minimal cost to the users, not merely on a non-profit
basis-- has yielded to profitability calculations. And, in most of
the rest, considerations of at least calculating and recovering costs
have crept in. While many of us feel some nostalgia for the old
system, it is clear that its days are waning if not gone: perhaps the
public service notions as understood when 1591 was written just don't
scale to rapid internet growth and very large numbers of
yregistrations.
In particular, some ccTLDs have advertised for registrations outside
the designated countries (or other entities), while others have made
clear decisions to allow registrations by non-nationals. These
decisions and others have produced protests from many sides,
suggesting, in turn, that a recategorization is in order. For
example, we have heard concerns by governments and managers of
traditional, "public service", in-country, ccTLDs about excessive
ICANN interference and fears of being forced to conform to
internationally-set policies for dispute resolution when their
domestic ones are considered more appropriate. We have also heard
concerns from registrars and operators of externally-marketed ccTLDs
about unreasonable government interference and from gTLD registrars
and registries about unreasonable competition from aggressively
marketed ccTLDs. The appropriate distinction is no longer between
what RFC 1591 described as "generic" TLDs (but which were really
intended to be "purpose-specific", a term I will use again below) and
ccTLDs but among:
(i) true "generic" TLDs, in which any registration is acceptable
and, ordinarily, registrations from all sources are actively
promoted. This list currently includes (the formerly purpose-
specific) COM, NET, and ORG, and some ccTLDs. There have been
proposals from time to time for additional TLDs of this variety in
which, as with COM (and, more recently, NET and ORG) anyone
(generally subject only to name conflicts and national law) could
register who could pay the fees.
(ii) purpose-specific TLDs, in which registration is accepted only
from organizations or individuals meeting particular
qualifications, but where those qualifications are not tied to
national boundaries. This list currently includes INT, EDU, the
infrastructure domain ARPA, and, arguably, the specialized US
Government TLDs MIL and GOV. There have been proposals from time
to time for other international TLDs of this variety, e.g., for
medical entities such as physicians and hospitals and for museums.
ICANN has recently approved several TLDs of this type and
describes them as "sponsored" TLDs.
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(iii) Country domains, operated according to the original
underlying assumptions of 1591, i.e., registrants are largely
expected to be people or other entities within the country. While
external registrations might be accepted by some of these, the
country does not aggressively advertise for such registrations,
nor does anyone expect to derive significant fee revenue from
them. All current domains in this category are ccTLDs, but not
all ccTLDs are in this category.
These categories are clearly orthogonal to the association between
the use of the IS 3166-1 registered code list [2] and two-letter
"country" domain names. If that relationship is to be maintained
(and I believe it is desirable), the only inherent requirement is
that no two-letter TLDs be created except from that list (in order to
avoid future conflicts). ICANN should control the allocation and
delegation of TLDs using these, and other, criteria, but only
registered 3166-1 two letter codes should be used as two-letter TLDs.
2. Implications of the Categories
If we had adopted this type of three-way categorization and could
make it work, I believe it would have presented several opportunities
for ICANN and the community more generally to reduce controversies
and move forward. Of course, there will be cases where the
categorization of a particular domain and its operating style will
not be completely clear-cut (see section 3, below). But having ICANN
work out procedures for dealing with those (probably few) situations
appears preferable to strategies that would tend to propel ICANN into
areas that are beyond its competence or that might require
significant expansion of its mandate.
First, the internally-operated ccTLDs (category iii above) should not
be required to have much interaction with ICANN or vice versa. Once
a domain of this sort is established and delegated, and assuming that
the "admin contact in the country" rule is strictly observed, the
domain should be able to function effectively without ICANN
intervention or oversight. In particular, while a country might
choose to adopt the general ICANN policies about dispute resolution
or name management, issues that arise in these areas might equally
well be dealt with exclusively under applicable national laws. If a
domain chooses to use ICANN services that cost resources to provide,
it should contribute to ICANN's support, but, if it does not, ICANN
should not presume to charge it for other than a reasonable fraction
of the costs to ICANN of operating the root, root servers, and any
directory systems that are generally agreed upon to be necessary and
in which the domain participates.
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By contrast, ccTLDs operated as generic domains ought to be treated
as generic domains. ICANN dispute resolution and name management
policies and any special rules developed to protect the Internet
public in multiple registrar or registry situations should reasonably
apply.
3. Telling TLD types apart
If appropriate policies are adopted, ccTLDs operated as generic
domains (category (i) above) and those operated as country domains
(category (iii) above) ought to be able to be self-identified. There
are several criteria that could be applied to make this
determination. For example, either a domain is aggressively seeking
outside registrations or it is not and either the vast majority of
registrants in a domain are in-country or they are not. One could
also think of this as the issue of having some tangible level of
presence in the jurisdiction - e.g., is the administrative contact
subject, in practical terms, to the in-country laws, or are the
registration rules such that it is reasonably likely that a court in
the jurisdiction of the country associated with the domain can
exercise jurisdiction and enforce a judgment against the registrant.
One (fairly non-intrusive) rule ICANN might well impose on all top-
level domains is that they identify and publish the policies they
intend to use. E.g., registrants in a domain that will use the laws
of one particular country to resolve disputes should have a
reasonable opportunity to understand those policies prior to
registration and to make other arrangements (e.g., to register
elsewhere) if that mechanism for dispute resolution is not
acceptable. Giving IANA (as the root registrar) incorrect
information about the purpose and use of a domain should be subject
to challenge, and should be grounds for reviewing the appropriateness
of the domain delegation, just as not acting consistently and
equitably provides such grounds under the original provisions of RFC
1591.
In order to ensure the availability of accurate and up-to-date
registration information the criteria must be consistent, and
consistent with more traditional gTLDs, for all nominally country
code domains operating as generic TLDs.
4. The role of ICANN in country domains
ICANN (and IANA) should, as described above, have as little
involvement as possible in the direction of true country [code]
domains (i.e., category (iii)). There is no particular reason why
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these domains should be subject to ICANN regulation beyond the basic
principles of 1591 and associated arrangements needed to ensure
Internet interoperability and stability.
ICANN's avoiding such involvement strengthens it: the desirability of
avoiding collisions with national sovereignty, determinations about
government legitimacy, and the authority of someone purportedly
writing on behalf of a government, is as important today as it was
when 1591 was written. The alternatives take us quickly from
"administration" into "internet governance" or, in the case of
determining which claimant is the legitimate government of a country,
"international relations", and the reasons for not moving in that
particular direction are legion.
5. The role of governments
The history of IANA strategy in handling ccTLDs included three major
"things to avoid" considerations:
* Never get involved in determining which entities were countries
and which ones were not.
* Never get involved in determining who was, or was not, the
legitimate government of a country. And, more generally, avoid
deciding what entity --government, religion, commercial,
academic, etc.-- has what legitimacy or rights.
* If possible, never become involved in in-country disputes.
Instead, very strongly encourage internal parties to work
problems out among themselves. At most, adopt a role as
mediator and educator, rather than judge, unless abuses are very
clear and clearly will not be settled by any internal mechanism.
All three considerations were obviously intended to avoid IANA's
being dragged into a political morass in which it had (and, I
suggest, has) no competence to resolve the issues and could only get
bogged down. The first consideration was the most visible (and the
easiest) and was implemented by strict and careful adherence (see
below) to the ISO 3166 registered Country Code list. If an entity
had a code, it was eligible to be registered with a TLD (although
IANA was free to apply additional criteria-most of them stated in
1591). If it did not, there were no exceptions: the applicant's only
recourse was a discussion with the 3166 Registration Authority (now
Maintenance Agency, often known just as "3166/MA") or the UN
Statistical Office (now Statistics Bureau), not with IANA.
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There are actually five ccTLD exceptions to the strict rules. One,
"UK", is historical: it predates the adoption of ISO 3166 for this
purpose. The others --Ascension Island, Guernsey, Isle of Man, and
Jersey --are arguably, at least in retrospect, just mistakes.
Regardless of the historical reasons (about which there has been much
speculation), it is almost certainly the case that the right way to
handle mistakes of this sort is to acknowledge them and move on,
rather than trying to use them as precedents to justify more
mistakes.
This, obviously, is also the argument against use of the "reserved"
list (technically internal to the 3166 maintenance activity, and not
part of the Standard): since IANA (or ICANN) can ask that a name be
placed on that list, there is no rule of an absolute determination by
an external organization. Purported countries can come to ICANN,
insist on having delegations made and persuade ICANN to ask that the
names be reserved. Then, since the reserved name would exist, they
could insist that the domain be delegated. Worse, someone could use
another organization to request reservation of the name by 3166/MA;
once it was reserved, ICANN might be hard-pressed not to do the
delegation. Of course, ICANN could (and probably would be forced to)
adopt additional criteria other than appearance on the "reserved
list" in order to delegate such domains. But those criteria would
almost certainly be nearly equivalent to determining which applicants
were legitimate and stable enough to be considered a country, the
exact decision process that 1591 strove to avoid.
The other two considerations were more subtle and not always
successful: from time to time, both before and after the formal
policy shifted toward "governments could have their way", IANA
received letters from people purporting to be competent government
authorities asking for changes. Some of them turned out later to not
have that authority or appropriate qualifications. The assumption of
1591 itself was that, if the "administrative contact in country" rule
was strictly observed, as was the rule that delegation changes
requested by the administrative contact would be honored, then, if a
government _really_ wanted to assert itself, it could pressure the
administrative contact into requesting the changes it wanted, using
whatever would pass for due process in that country. And the ability
to apply that process and pressure would effectively determine who
was the government and who wasn't, and would do so far more
effectively than any IANA evaluation of, e.g., whether the letterhead
on a request looked authentic (and far more safely for ICANN than
asking the opinion of any particular other government or selection of
governments).
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Specific language in 1591 permitted IANA to adopt a "work it out
yourselves; if we have to decide, we will strive for a solution that
is not satisfactory to any party" stance. That approach was used
successfully, along with large doses of education, on many occasions
over the years, to avoid IANA's having to assume the role of judge
between conflicting parties.
Similar principles could be applied to the boundary between country-
code-based generic TLDs and country domains. Different countries,
under different circumstances, might prefer to operate the ccTLD
either as a national service or as a profit center where the
"customers" were largely external. Whatever decisions were made
historically, general Internet stability argues that changes should
not be made lightly. At the same time, if a government wishes to
make a change, the best mechanism for doing so is not to involve
ICANN in a potential determination of legitimacy (or even to have
ICANN's Government Advisory Committee (GAC) try to formally make that
decision for individual countries) but for the relevant government to
use its own procedures to persuade the administrative contact to
request the change and for IANA to promptly and efficiently carry out
requests made by administrative contacts.
6. Implications for the current ICANN DNSO structure.
The arguments by some of the ccTLD administrators that they are
different from the rest of the ICANN and DNSO structures are (in this
model) correct: they are different. The ccTLDs that are operating as
generic TLDs should be separated from the ccTLD constituency and
joined to the gTLD constituency. The country ccTLDs should be
separated from ICANN's immediate Supporting Organization structure,
and operate in a parallel and advisory capacity to ICANN, similar to
the arrangements used with the GAC. The DNSO and country TLDs should
not be required to interact with each other except on a mutually
voluntary basis and, if ICANN needs interaction or advice from some
of all of those TLDs, it would be more appropriate to get it in the
form of an advisory body like the GAC rather than as DNSO
constituency.
7. References
[1] Postel, J., "Domain Name System Structure and Delegation", RFC
1591, March 1994.
[2] ISO 3166. ISO 3166-1. Codes for the representation of names of
countries and their subdivisions - Part 1: Country codes (1997).
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8. Acknowledgements and disclaimer
These reflections have been prepared in my individual capacity and do
not necessarily reflect the views of my past or present employers.
Several people, including Randy Bush, Theresa Swinehart, Zita Wenzel,
Geoff Huston, Havard Eidnes, and several anonymous reviewers, made
suggestions or offered editorial comments about earlier versions of
this document. Cord Wischhoefer, of the ISO 3166/MA, was also kind
enough to look at the draft and supplied some useful details. Those
comments contributed significantly to whatever clarity the document
has, but the author bears responsibility for the selection of
comments which were ultimately incorporated and the way in which the
conclusions were presented.
9. Security Considerations
This memo addresses the context for a set of administrative decisions
and procedures, and does not raise or address security issues.
10. Author's Address
John C. Klensin
1770 Massachusetts Ave, Suite 322
Cambridge, MA 02140, USA
EMail: klensin@jck.com
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