IANA Report on the Redelegation of the .BM Top-Level Domain

Background

The Internet Assigned Numbers Authority (IANA) function of ICANN, as part of the administrative tasks associated with management of the Domain Name System root zone, is responsible for receiving requests for the delegation and redelegation of top-level domains, investigating and reporting on the circumstances pertinent to those requests, and, when appropriate, implementing the redelegations.

In accordance with ICANN’s performance of these functions, IANA received a request for the redelegation of the .BM top-level domain on 8 March 2007. This domain is designated in the ISO 3166-1 standard for Bermuda, a British overseas territory located in the Carribean with a population of approximately 66,000.

The initial delegation information IANA has available shows that the earliest assigned administrative and technical contact was Tom Coehlho, the Director of Computer Services at the Bermuda College. The currently listed Sponsoring Organisation for the domain is Bermuda College. The contact persons have subsequently been updated to reflect staffing changes at the college.

In August 2003, IANA received a request to redelegate the .BM top-level domain to the Ministry of Tourism, Telecommunications and E-Commerce. In support of the request, IANA received a letter the Ministry explaining that the current sponsoring organisation had advised the Government that it wished to relinquish their responsibility for management the .BM domain. The letter also expressed the Government’s full support of the redelegation.

In response, IANA advised the applicants of the additional documentation necessary to proceed with a redelegation request. This was followed by several discussions with the requestors clarifying the requirements. The request was administratively closed by IANA in March 2005 due to the lack of supplemental documentation.

On 26 April 2007, IANA received a letter from the sponsoring organisation, Bermuda College, explaining that it had transferred responsibility for administration for the .BM domain to the Registrar General of Bermuda. The letter requested IANA update its records to reflect the changes in administrative and technical contacts. In responsible to the letter, IANA replied with an explanation of the redelegation process, and requested the additional information required to proceed.

On 8 May 2007, a new redelegation request was lodged with IANA. The requests seeks delegation of .BM to the Registry General of the Bermudan Ministry of Labour and Immigration. It is proposed that the Registrar General, Marlene Christopher, act as Administrative Contact. The technical contact would be fulfilled by a role account of the Information Technology Office of the Government of Bermuda.

Evaluation Procedure

In its role as investigator of delegation and redelegation requests, IANA is guided by the practices summarized in:

In considering the delegation or redelegation of a ccTLD, IANA seeks input from both the requesting party as well as from persons and/or organizations that may be significantly affected by the change, particularly those within the nation or territory to which the ccTLD is designated. As noted in ICP-1, the parties affected include the relevant government or public authority: "The desires of the government of a country with regard to delegation of a ccTLD are taken very seriously. The IANA will make them a major consideration in any TLD delegation/transfer discussions."

Taking these factors into consideration, the burden of proof required to permit a delegation involves determining facts that relate to the applicant’s capacity to meet the following criteria:

  1. Operational and technical skills

    1. The prospective manager has the requisite skills to operate the TLD appropriately. (ICP-1 §a, RFC 1591 §3.5)
    2. There must be reliable, full-time IP connectivity to the nameservers and electronic mail connectivity to the operators; (ICP-1 §a; RFC 1591 §3.1)
    3. The manager must perform its duties in assigning domains and operating nameservers with technical competence (ICP-1 §d; RFC 1591 §3.5)

  2. Operator in country

    1. The prospective manager supervises and operates the domain name from within the country represented by the TLD; (ICP-1 §a; RFC 1591 §3.1)
    2. The prospective administrative contact must reside in the country represented by the TLD. (ICP-1 §a; RFC 1591 §3.1)

  3. Equitable treatment

    1. The prospective manager must be equitable and fair to all groups encompassed by the TLD that may request domain names (ICP-1 §c; RFC 1591 §3.3)

  4. Community/Governmental support

    1. The prospective manager has the requisite authority to operate the TLD appropriately, with the desire of the government taken very seriously. (ICP-1 §a, GAC Principles)
    2. Significantly interested parties in the domain should agree that the prospective manager is the appropriate party to receive the delegation (ICP-1 §a; RFC 1591 §3.4)

In meeting these criteria, the IANA requests information from the applicant. In summary, a request template is sought specifying the exact details of the delegation being sought in the root zone. In addition, IANA asks for various documentation describing: the views of the local Internet community on a change; the competencies and skills of the organisation to operate the registry; the legal authenticity, status and character of the proposed operator; and the nature of government support for the proposal.

After receiving these documents, IANA analyses the input it has received in relation to existing zone management procedures, seeking input from parties both related to as well as independent of the applying organization should the information provided by the applicant in their request be deficient.

Once all the documentation has been received, IANA will also perform various technical checks on the proposed operator’s DNS infrastructure to ensure name servers are properly configured and are able to respond to queries for the top-level domain being requested. Should any anomalies be detected in the applicant’s technical infrastructure, IANA will work with the applicant to address the issues.

Assuming all technical issues are resolved, IANA will compile a report, providing all relevant details regarding the applicant, its suitability for operating the top-level domain being requested, and any other information pertinent to the application and submit that report to ICANN’s Board of Directors for its determination on whether to proceed with the request.

Evaluation

This report is being provided under the contract for performance of the IANA function between the United States Government and ICANN. Under that contract, ICANN performs the IANA function, which includes receiving delegation and redelegation requests concerning top-level domains, investigating the circumstances pertinent to those requests, and reporting on the requests.

Pertaining to the obligations described in the evaluation procedure, in summary IANA has assessed the applicant’s credentials to be as follows:

Recommendation

According to RFC 1591 and ICP-1, IANA needs to respect the ability for a local Internet community as well as local law and local government to make decisions about the operation of a TLD.

In its research, IANA believes that there are grounds for reassignment of the domain name under the relevant criteria. The current operators have stated that they are no longer managing the domain and that the proposed operators have been the entity in charge for a number of years.

IANA therefore concludes that the .BM domain should be redelegated to the Office of the Registrar General, Ministry of Labour and Immigration of Bermuda as per their request.

Postscript: Board Resolution

On 16 October 2007 the Board of ICANN passed the following resolution:

Whereas, the .BM top-level domain is the designated country-code for Bermuda;

Whereas, ICANN has received a request for redelegation of .BM to the Registrar General of Bermuda;

Whereas, ICANN has reviewed the request, and has determined that the proposed redelegation would be in the best interest of the local and global Internet communities.

It is hereby resolved (07.81), that the proposed redelegation of the .BM domain to the Registrar General of Bermuda is approved.