.wales – please fill in the Nominet consultation

[bulkcorn]

Directly link the registries so that if someone registers example.cymru then the same label in the other domain (i.e. example.wales) is reserved for use by the registrant and vice versa.

Rather than automatically reserve the alternative domain name as set out in option 1 above, offer the registrant first refusal of the alternative domain name (if it is not already registered) at a reduced rate. If this is not taken up by the registrant then the alternative name will be available for registration.

The above options as offered in the .cymru/.wales weren't offered in the .uk consultation. They should have been offered.

 

[getmein]

As an existing registry, I suspect they will be able to provide the registry side of the service at well below $2million that .nyc have suggested. But the difficulty in actually coming up with a number for the running costs between the various registries Nominet will be responsible for is problematic. Particularly, the danger of cross subsidising from .uk.

On the income side of things, it remains to be seen what pricing and uptake will be. I don't think they have the pricing power of something like .law, nor the popularity of something like .web. But it may well be, that Nominet consider the importance of running these registries takes primacy to their commercial success. Having said that, unlike some of the bizarre gTLD applications (IMO) I think these are reasonable strings to try and release.

A key difference is that unlike some of the 'portfolio' gTLD applicants, who I'm sure will be quite prepared to dump strings that don't prove to be commercially viable - I think Nominet would have to continue to support the registries even if they consistently operate at a loss (there would be huge reputational and commercial danger to them if they didn't). For that reason, I think they should at the very least share the risk with the Welsh Assembly.

On a relative basis the consultation seems better thought out than direct.uk but I'm amazed they can't see the inconsistencies (e.g. optional DNSSEC) between this and direct.uk. Hopefully they'll now be able to understand, that while their proposed release mechanism for a brand new gTLD is reasonable - trying to copy it over to direct.uk was ludicrous given the clear differences between the current .uk domains that would be prejudiced by a new, similar and shorter domain and a brand new gTLD.

 

[bulkcorn]

On a relative basis the consultation seems better thought out than direct.uk but I'm amazed they can't see the inconsistencies (e.g. optional DNSSEC) between this and direct.uk. Hopefully they'll now be able to understand, that while their proposed release mechanism for a brand new gTLD is reasonable - trying to copy it over to direct.uk was ludicrous given the clear differences between the current .uk domains that would be prejudiced by a new, similar and shorter domain and a brand new gTLD.

Exactly! The 'spirit' of this cymru/wales consultation appears to be very different to that of the direct.uk!

 

[Nigel]

Will the $2m annual cost of running the .nyc domain (which Nominet have used in the consultation brochure as an example) be higher than running .wales? I think the .wales extension has extra features that will be more expensive and a lot more complex.

Consider that .nyc are only running the single domain, using one language, wheras Nominet have purchased the rights to two domains .wales and .cymru. I read that these gtlds cost $185,000 each up front - followed by an annual charge of $25,000 each. So Nominet will, I assume, have already spent $370,000 up front on just the intitial registration costs. That's an enormous registration fee for a total population of just 3m.

Then consider the fact that the Welsh speaking part of that population (i.e. the ones likely to be interested in .cymru) is only estimated at 20% which equates to just 600,000 people. That's far less than a lot of English counties but Nominet will have paid full rate to buy the rights to this domain. I also assume that Nominet will need more than 2 staff on hand (i.e. to cover holidays, etc) who can speak fluent Welsh. So it could mean that some .wales staff might not be able to operate across both domains if you cannot speak fluent welsh.

Then you've got the complex situation that Bulkcorn mentioned earlier where Nominet are suggesting offering deals on clients buying the .wales or .cymru together, possibly at reduced rates. It does seem as if Nominet are going out of their way to accommodate the .wales and .cymru domains. But then they've spent a small fortune already.

Maybe some of my assumptions aren't right but that's the way I see this. If anyone else has got ideas on costing then pleased to hear them. Notice that Nominet gave no indication of the complexities and extra costs in terms of ICANN fees, staffing etc in their consultation document. They just quoted the costs of .nyc - which I don't believe is an accurate indicator at all. I am concerned that a lot of the extra costs will just be buried. Why haven't they even produced staffing costs?

 

[getmein]

Marketing is an unknown cost - in some part contingent on whether they'll relax their stance on emailing current .uk registrants based in Wales. I suspect they'd get a fair amount of PR coverage at low cost.

The $370k upfront is already gone, but much of that is a one-off cost. If the project bombs commercially I think they could spent/waste a multiple of that in the future. If it's successful, then seen over 10 years the upfront costs aren't too onerous.

I agree that the performance of cymru/wales are likely to be different and as you point out there are some characteristics of cymru which mean they probably can't run that registry without registry specific additional costs.

 

[Nigel]

I imagine that Nominet have already spent double that $370k in legal fees, consultants, drawing up the consultation document, meetings etc. I cannot see why Nominet would choose to run such a complex registry. It's not as if there weren't a large group of Welsh people who would have gladly run .cymru. I agree with an earlier post that said a lot of Welsh people will not like the fact that their registry is run in England. Here's a few excerpts from the English pages of the dotcym.org site - these are the Welsh people that lost out to Nominet.

http://www.dotcym.org/home/?p=166

"•dotCYM was created to cooperate with the Welsh Government on a top-level domain for Wales and the Welsh community worldwide and has been working with the Government on this understanding for years. The Government has now reneged on its promise of a £300,000 loan to dotCYM and created a criteria which would need an extra $185,000 on top of that original sum. dotCYM is expected to be able to compete against Nominet in this ‘fair competition’."

"•There is no funding for this project from the government. A Welsh top-level domain will be an important addition to Wales’ infrastructure and it’s important for Welsh economy. It’s an excellent tool to promote Welsh culture and language and to create a closer network with the Welsh diaspora. But the government does not deem it necessary to fund such a project – even with a loan that will be quickly repaid. Why? Because there’s a company in England that’s offering to do it all for free...."

And on this page:
http://www.dotcym.org/home/?p=174
'dotCYM is currently going through the process of dissolving. The Members voted in the AGM to close the company since there is no reason for the continuation of the company after the Welsh Government gave ownership of the Welsh name and brand online to a private English company that’s not answerable to the Welsh people.

and on this page:
http://www.dotcym.org/home/

"Months have passed with no news from the Government and we await the beginning of the competition against Nominet, where we must try to ensure that the Welsh keep ownership and control of their top-level domain, against a large corporation that already has a monopoly in the UK domain market and wants to defend it - and has Government officials’ support to do so."

 

[Stephen]

...... Here's a few excerpts from the English pages of the dotcym.org site - these are the Welsh people that lost out to Nominet.

http://www.dotcym.org/home/?p=166

"•dotCYM was created to cooperate with the Welsh Government on a top-level domain for Wales and the Welsh community worldwide and has been working with the Government on this understanding for years.....

Thanks very much, all fascinating stuff.

If a lot of English domainers don't trust Nominet at the moment, what are the Welsh going to think?

Are there any domainers here that thinks they will try to invest in .wales?

 

[Nigel]

I think a lot of those people will probably boycott the new domains. Shame this thread isn't open to the public like the '.uk announced' one. Then some of them might log in and tell us.

I'm sure it would comfort them to know that a lot of members do not agree with Nominet muscling in on their dream to run their own registry based in Wales. So who made the decision at Nominet to bid for .wales and .cymru? Was this debated by the members and put to a vote?

 

[Stephen]

Welsh advisory Board

..... So who made the decision at Nominet to bid for .wales and .cymru? Was this debated by the members and put to a vote?

I could not find any Nominet registrar vote.

This is the first item I could find from 2011 (no date supplied)

http://www.domainforwales.org.uk/news/nominet-announces-key-advisors-wales

I wonder if the advisory board got extra pay/fees?

I didn't see such talent assembled to consider the .uk impact?

Here is what they said about the Welsh advisory Board, Nominet put together

“We have assembled an initial Advisory Group consisting of leading thinkers, those who have shown an interest in developing the application, and who more importantly wish to see Wales have a domain name to position itself in the World."

 

[Nigel]

I could not find any Nominet registrar vote.

This is the first item I could find from 2011 (no date supplied)

http://www.domainforwales.org.uk/news/nominet-announces-key-advisors-wales

I wonder if the advisory board got extra pay/fees?

I didn't see such talent assembled to consider the .uk impact?

Here is what they said about the Welsh advisory Board, Nominet put together

Thanks for looking into that. I can't quite believe that such a massive investment would not be subject to a debate and vote by Nominet members. I'm not a tagholder but its things like this that makes me want to apply. Even then what can you do to hold the nominet executive to account?

 

[Whois-Search]

You will find more information about the applications here:

http://gtldresult.icann.org/applica...iondetails:downloadapplication/1420?t:ac=1420

http://gtldresult.icann.org/applica...iondetails:downloadapplication/1419?t:ac=1419

Found on:
http://gtldresult.icann.org/application-result/applicationstatus/viewstatus

Also Nominet have a webinar on Tuesday for questions:
http://www.domainforwales.org.uk/news/new-domains-wales-webinar-your-questions-answered

 

[Edwin]

From the above documents, they're not exactly going to be bunging a lot of resources at running .wales...

Resource plan
Nominet have fully developed the SRS systems with pre-launch testing to be done in 2012. We have a development team of 16 staff, an infrastructure team of 15 staff and a customer support team of 24 staff. All these staff are experienced in running the dot UK services. We will dedicate the following resources and time from these existing teams, as well as additional resources where appropriate, to the pre-launch and post launch maintenance tasks:

Pre-launch
- Testbed deployment: 10 days by a system administrator
- Testing: 15 days by a developer
- Packaging: 2 days by a developer
- Production deployment: 10 days by a system administrator
Total pre-launch resource time: 37 days.

6 months immediately following launch
- Customer support: 8 hours per week
- Technical support: 4 hours per week
Total resource in the 6 months immediately following launch: 12 hours per week

Ongoing business as usual
- Customer support: 4 hours per week
- Technical support: 4 hours per week
Total ongoing business as usual resource: 8 hours per week

Thus, on the staff side at least, their costs (both initial and ongoing) to run .wales will be utterly insignificant in relation to the overall size of their operation.

 

[Nigel]

I can't believe those figures Edwin. 8 hours a week of customer support for the 6 months following launch and 4 hours a week thereafter. Sounds nonsense to me. So I just did another search on this. This is what was reported last year:

"Nominet, which manages the .uk domain name from its head office in Oxford, said it was committed to establishing an office base in Wales to deliver the ".wales’’ and ".cymru" domain names - creating up to nine jobs in the process."

and in the same article Lesley Cowley said:

"We will run the domains on a fully-bilingual basis and we will publish our own Welsh Language Scheme in due course.’’

Something doesn't add up - says 'nine jobs' and an office in Wales - well at least that's what they were saying then - here's the link to the South Wales Argus article:

http://www.southwalesargus.co.uk/news/gwentnews/9629165.Wales_bids_for_web_domain_names/

 

[Paullas]

At least they have the office all ready for them.

 

[Whois-Search]

Outsourced

See this Nominet put out in December:

In order to ensure that we can provide a bilingual support service for the new domains, Nominet is looking for a supplier who can provide an outsourced English and Welsh speaking customer service team. We have developed an RFP and invite submissions from providers of such services.

http://www.nominet.org.uk/news/late...r-support-service-dotcymru-and-dotwales-gtlds

 

[Nigel]

See this Nominet put out in December:

http://www.nominet.org.uk/news/late...r-support-service-dotcymru-and-dotwales-gtlds

Thanks for that - they forgot to say that they'll only need the service for an hour a day!

 

[Stephen]

From the above documents, they're not exactly going to be bunging a lot of resources at running .wales...

Thus, on the staff side at least, their costs (both initial and ongoing) to run .wales will be utterly insignificant in relation to the overall size of their operation.

Thanks for pointing that out.

But I would like to know who many domains they expect to sell and the number of the extra staff numbers they are invisaging before I could make a final judgement if they are reasonable.

But based on my business experience and the scant information we have been given that is not going to be enough resources on what I think they would need on a new product such as .wales.

 

[Murray]

I honestly can't believe that many people will be interested in having a .wales

I know if there was a .england the only reason i would want one would be the possibility of selling it.

I could imagine the majority of initial registrations would be domainers being speculative.. after that, not much at all.

 

[Nigel]

Nominet's 'office in Wales' story with 'nine jobs', and fully bilingual service also appeared in the North Wales Newspaper - The Daily Post. Here's the link:
http://www.dailypost.co.uk/news/nor...-bids-for-online-domain-names-55578-30687360/

 

[GreyWing]

This is borderline illegal what Nominet is doing in my opinion. You can't use profits from one market to subsidies another, it's called anti competitive practises or abuse of a dominant position.

For example supermarkets would love to sell petrol at prices below cost to get people through to their venue, subsidies from their grocery side but they aren't allowed to do so. So in effect they are putting other independent petrol stations out of business.

http://www.expressandstar.com/news/2012/09/16/fuel-price-wars-hit-small-petrol-stations/

If Nominet is running this at a loss then it is in my opinion a abuse of a dominant position and you can complain to the OFT. I think it will be run at a loss, I can't see how it is commercially viable to run without .uk's subsidising it. That is a big big no no.

http://www.oft.gov.uk/shared_oft/business_leaflets/ca98_guidelines/oft402.pdf

5.5

Categories of abuse
5.5 Abusive conduct generally falls into one or both of the following
categories:
• conduct which exploits customers or suppliers (for example,
excessively high prices), or
• conduct which amounts to exclusionary behaviour, because it
removes or weakens competition from existing competitors, or
establishes or strengthens entry barriers, thereby removing or
weakening potential competition.

5.6 Exclusionary behaviour may include excessively low prices and certain
discount schemes, where its (likely) effect is to foreclose a market, as
well as vertical restraints or refusals to supply where these (are likely
to) foreclose markets or dampen competition. However, whatever the
form of the behaviour in question, its likely effect on competition will
depend on the circumstances at hand and the OFT assesses alleged
abuses on a case-by-case basis.

Abuse in related markets
5.7 As explained at paragraph 4.1 above, Article 82 and the Chapter II
prohibition imply two tests: whether an undertaking is dominant, and
whether it is abusing that dominant position. It is not necessary to
show that the abuse was committed in the market which the
undertaking dominates. In certain circumstances, Article 82 and the
Chapter II prohibition may apply where an undertaking that is
dominant in one market commits an abuse in a different but closely
associated market. This principle was set out by the European Court
in the case of Tetra Pak II
24
.

The OFT may block it, someone may want to drop them a line and report it.