Report on the Transfer of the .TR (Turkey) country-code top-level domain to Bilgi Teknolojileri ve İletişim Kurumu (BTK)

17 April 2019

This report is a summary of the materials reviewed as part of the process for the transfer of the .TR (Turkey) country-code top-level domain. It includes details regarding the proposed transfer, evaluation of the documentation pertinent to the request, and actions undertaken in connection with processing the transfer.

Factual Information

Country

The “TR” ISO 3166-1 code from which the application’s eligibility derives, is designated for use to represent Turkey.

Chronology of events

In 1991, the .TR top-level domain was delegated to the Middle East Technical University (METU). The University continues to operate the domain to this day.

In 2000, Amendment 5 of the Wireless Law 2813 established the Telekomünikasyon Kurumu (translated as the Telecommunications Authority), a public legal entity in Turkey with public administrative and financial autonomy to conduct the regulation and supervision function of the telecommunications sector.

In 2008, Article 65(3) of the Electronic Communication Act No. 5809 changed the authority’s name to Bilgi Teknojileri ve İletişim Kurumu (BTK), translated as the Information and Communication Technologies Authority. Articles 5(1)(a) and 35 of the Act give the Ministry of Transport the responsibility to “determine the strategies and policies concerning the electronic communications services based on scarce resources, such as numbering, internet domain names, satellite positions, and frequency allocations” and to determine the “organizations or institutions, which shall carry out registrations of internet domain names, and the principles and procedures concerning the management of domain names”.

In 2009, the Ministry conducted several consultation sessions with significantly interested parties to prepare what became the Bylaw on Internet Domain Names. According to Article 1 of the Bylaw, its purpose “is to regulate the principles and procedures regarding ‘.tr’ country code top level Internet domain names management.”

On 7 November 2010, the Ministry published the Bylaw on Internet Domain Names, giving BTK, as the information and communications technologies authority, the responsibility of managing the .TR top-level domain. Articles 14 and 15 of the Bylaw define the “Duties and Powers of the Authority”, which include setting up and operating, or having a third party set up and operate, the structure, systems and processes to manage the .TR top-level domain.

On 21 December 2018, after several years of discussions, METU and BTK signed an agreement regarding a .TR top-level domain transition process and commenced a transfer request with IANA. The agreement provides for a 42-month timeline during which METU will provide training and hands-on experience for BTK staff as well as operate the .TR top-level domain under contract from BTK through the training period. As such, this transfer will not initially involve the transfer of the technical operations for the .TR top-level domain.

Proposed Manager and Contacts

The proposed manager is Bilgi Teknolojileri ve İletişim Kurumu (BTK), a governmental entity granted operational responsibility for the .TR top-level domain according to the country’s laws. It is based in Turkey.

The proposed administrative contact is Sezen Yeşil, an ICT Expert with the Bilgi Teknolojileri ve İletişim Kurumu. The administrative contact is understood to be based in Turkey.

The proposed technical contact is Onur Gençer, an ICT Expert with the Bilgi Teknolojileri ve İletişim Kurumu.

Evaluation of the Request

String Eligibility

The top-level domain is eligible for transfer as the string for Turkey is presently listed in the ISO 3166-1 standard.

Incumbent Consent

The incumbent manager is the Middle East Technical University. Informed consent for the transfer of .TR top-level domain to Bilgi Teknolojileri ve İletişim Kurumu (BTK) was provided by Prof. Dr. Mustafa Verşan Kök, Rector of the Middle East Technical University.

Public Interest

Government support was provided by Dr. Ömer Fatih Sayan, the Deputy Minister of Transport and Infrastructure. Additional support letters were provided by the following:

• Associate Professor Dr. Leyla Keser, Director, IT Law Institute, Istanbul Bilgi University.
• Professor Dr. Şeref Sağiroğlu, Head of the Computer Engineering Department, Gazi University.
• Professor Dr. Bulent Kent, General Secretary of the Association of Access Providers (ESB), an association that represents the local Internet community in Turkey.

The application is consistent with known applicable laws in Turkey. The proposed manager undertakes the responsibility to operate the domain in a fair and equitable manner.

Based In Country

The proposed manager is constituted in Turkey. The administrative contact is understood to be a resident of Turkey. The registry is to be operated in Turkey.

Stability

The application does not involve a transfer of domain operations from an existing domain registry, and therefore stability aspects relating to registry transfer are not relevant.

The application is not known to be contested.

Competency

The application has provided information on the technical and operational infrastructures and expertise that will be used to operate the domain.

Proposed policies for management of the domain have also been tendered.

Evaluation Procedure

PTI is tasked with coordinating the Domain Name System root zone as part of a set of functions governed by a contract with ICANN. This includes accepting and evaluating requests for delegation and transfer of top-level domains.

A subset of top-level domains is designated for the significantly interested parties in countries to operate in a way that best suits their local needs. These are known as country-code top-level domains (ccTLDs), and are assigned to responsible managers that meet a number of public-interest criteria for eligibility. These criteria largely relate to the level of support the manager has from its local Internet community, its capacity to ensure stable operation of the domain, and its applicability under any relevant local laws.

Through the IANA Services performed by PTI, requests are received for delegating new ccTLDs, and transferring or revoking existing ccTLDs. An investigation is performed on the circumstances pertinent to those requests, and, the requests are implemented where they are found to meet the criteria.

Purpose of evaluations

The evaluation of eligibility for ccTLDs, and of evaluating responsible managers charged with operating them, is guided by a number of principles. The objective of the assessment is that the action enhances the secure and stable operation of the Internet’s unique identifier systems.

In considering requests to delegate or transfer ccTLDs, input is sought regarding the proposed new manager, as well as from persons and organizations that may be significantly affected by the change, particularly those within the nation or territory to which the ccTLD is designated.

The assessment is focused on the capacity for the proposed manager to meet the following criteria:

• The domain should be operated within the country, including having its manager and administrative contact based in the country.
• The domain should be operated in a way that is fair and equitable to all groups in the local Internet community.
• Significantly interested parties in the domain should agree that the prospective manager is the appropriate party to be responsible for the domain, with the desires of the national government taken very seriously.
• The domain must be operated competently, both technically and operationally. Management of the domain should adhere to relevant technical standards and community best practices.
• Risks to the stability of the Internet addressing system must be adequately considered and addressed, particularly with regard to how existing identifiers will continue to function.

Method of evaluation

To assess these criteria, information is requested from the applicant regarding the proposed manager and method of operation. In summary, a request template is sought specifying the exact details of the delegation being sought in the root zone. In addition, various documentation is sought describing: the views of the local internet community on the application; the competencies and skills of the manager to operate the domain; the legal authenticity, status and character of the proposed manager; and the nature of government support for the proposal.

After receiving this documentation and input, it is analyzed in relation to existing root zone management procedures, seeking input from parties both related to as well as independent of the proposed manager should the information provided in the original application be deficient. The applicant is given the opportunity to cure any deficiencies before a final assessment is made.

Once all the documentation has been received, various technical checks are performed on the proposed manager’s DNS infrastructure to ensure name servers are properly configured and are able to respond to queries correctly. Should any anomalies be detected, PTI will work with the applicant to address the issues.

Assuming all issues are resolved, an assessment is compiled providing all relevant details regarding the proposed manager and its suitability to operate the relevant top-level domain.