The Internet Corporation for Assigned Names and Numbers (ICANN) is tasked with managing the Domain Name System root zone as part of a set of functions governed by a contract with the US Government. Through an ICANN department known as the Internet Assigned Numbers Authority (IANA), it receives requests for delegating and redelegating the operation of top-level domains. An investigation is performed on the circumstances pertinent to those requests, and, when appropriate, the requests are implemented. Decisions on whether to implement requests to delegate or redelegate top-level domains are made by the ICANN Board of Directors, taking into account ICANN’s core mission to ensure the stable and secure operation of the Internet’s unique identifier systems.
A subset of top-level domains are designated for the local Internet communities in countries to operate in a way that best suits their local needs. These country-code top-level domains are assigned to responsible trustees (known as ‘Sponsoring Organisations’) who meet a number of established criteria for eligibility — largely relating to their level of support from their local Internet community, their capacity to ensure stable operation of the domain, and their applicability under any relevant local laws.
In accordance with this, a request was received for the redelegation of the .SO top-level domain on 20 June 2008. This domain is designated in the ISO 3166-1 standard for Somalia, a country located in north-eastern Africa with a population of 9.5 million people.
The initial delegation of the .SO domain was performed in 1997 to World Class Domains, a US enterprise. This organisation remains the currently designated Sponsoring Organisation for the .SO domain.
Since at least 2002, the URL to the Sponsoring Organisation’s web site has intermittently contained a message:
As Somalia has no internationally recognized government, this domain is not currently used. We simply have parked this top level domain till an official government is implemented.
If you are looking for information about Somalia, please visit Yahoo’s Somalia category or the United Nations Somalia page.
No .SO domains are available and we are not looking for any registrar partners.
For an extended period, the delegation of .SO has been “lame”. This means that none of the authoritative name servers have worked, essentially making the domain completely dysfunctional. Furthermore, attempts to directly contact the listed contacts for .SO by IANA staff have resulted in failure. Deliver has been attempted on the postal address listed without success.
As at late-2008, the functioning of the .SO zone has been partially restored, and the contents of the zone appear to be largely unchanged since 2002 — consistent with the statement on the Sponsoring Organisation’s web page. The are only two known existing hosts registered within the domain, apart from those relating to the registry operation itself. The authorities for .SO have significant technical conformance issues, for example, there is a complete mismatch between the authorities named in the root, and in the child zone; only two of the three authorities in the root answer authoritatively; and only one of the two authorities listed in the child zone answer authoritatively.
The application for redelegation of .SO has been put forward by the International Telecommunications Union (ITU), who has entered into an agreement with the Federal Democratic Republic of Somalia, to:
... make available and to encourage Somali public and private sector entities to use the Somali .so country code Top Level Domain (ccTLD) which is currently non-functioning. (1.1.2)
... assist in the re-delegation, consideration and development of associated policies, associated training and transitional arrangements for Somalia to assume the management of the .so ccTLD. (1.2)
The agreement was executed between Mr Abdi Mohamed Tarrah, Minister of Posts and Telecommunications for Somalia; and Mr Sami Al Basheer Al Morshid, Director of the Telecommunication Development Bureau of the ITU.
The application proposes that a new .SO registry be established by a “leading DNS expert acting under instructions from the Ministry for Posts and Telecommunications”, allowing for “basic name registrations for government, NGOs, relief agencies and other stakeholders”. It then states at a later date, a registry operated by Somali nationals will be established, although likely will be based in another country such as the United Arab Emirates or Kenya.
One letter of support was received in conjunction with the application, from the CEO of Dalkom Somalia, endorsing the redelegation on behalf of the Somali Internet and Telecommunication Association. Despite this, the application asserts that “to all intents and purposes there is no local Internet community of ISPs, user groups, trade associations or a national ISOC chapter.”
On 19 November 2008, a transmission was received by IANA Root Management from Aveek Datta, responding on behalf of the Technical Contact of the .SO domain. In prior correspondence, Mr Datta has identified himself as the President of Monolith Innovation Group, Inc. In the communication, he explained that they are “holding this top-level domain in trust for the people of Somalia as their government is currently in disarray. I do have a contact of Somalia origins that has agreed with this course of action.” They asked what the process is to object to this redelegation request as the current registry for the domain.
In response, the complainant was asked to verify their connection with World Class Domains, with a view towards clarifying the history of the delegation as well as identifying what substantive issues they had with respect to the redelegation request. Despite several reminders, no further response has been received from the technical contact.
The evaluation of a delegation or redelegation request is guided by the practices summarised in:
“Domain Name System Structure and Delegation” (RFC 1591). This document describes IANA function practices relating to delegations at its publication in 1994.
“Internet Domain Name System Structure and Delegation” (ICP-1). This document represents an update of the portions of RFC 1591 dealing with ccTLDs and reflects subsequent evolution of the policies followed by ICANN through May 1999.
The ICANN Governmental Advisory Committee’s Principles for Delegation and Administration of ccTLDs (GAC Principles). This document serve as “best practices” to guide governments in assuming proper roles with respect to the Internet's naming system.
In considering the delegation or redelegation of a ccTLD, ICANN seeks input from both the current manager and the prospective manager 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 action involves determining facts that relate to the applicant’s capacity to meet the following criteria:
In meeting these criteria, information is requested 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, various documentation is sought 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. The view of the current operator is obtained, and in the event of a redelegation, the transfer plan from the previous operator to the new operator is also assessed with a view to ensuring ongoing stable operation of the domain.
After receiving these documents, the input received is analysed 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, various technical checks are performed 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, ICANN staff will work with the applicant to address the issues.
Assuming all issues are resolved, a report is compiled 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.
This evaluation is being provided to the ICANN Board for consideration and decision, as part of 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.
The evaluation of the various criteria relating to the request are as follows:
The applicant has not articulated a comprehensive operational plan, rather describing an evolutionary roadmap with phases of operation for the domain. The first phase consists of “a leading DNS expert acting under instructions from the Ministry for Posts and Telecommunications”. This expert will “allow for basic name registrations for branches of government, NGOs, relief agencies and other stakeholders. The objective is to facilitate web and email services for the Somali government and others who are assisting in the country's relief efforts”. This method of operation would last 1-2 years, after which time it is expected a more formal registry operation will be devised in concert with the local Internet community.
The proposed Sponsoring Organisation is the Ministry of Post and Telecommunications. However, the application describes that the proposed operation of the domain will not be conducted within the country — both in the short term, and likely in the longer term.
The requirement that the operator be in the country revolves around the capacity for the local Internet community and other relevant interests to have the registry within a reasonable scope to influence it actions. When a registry is outside of the country, legal remedies - for example - are limited when the local law can not be applied to the operator. Furthermore, should the operator fail for some reason, without having the data locally (or in escrow, or similar) it may not be possible to recover the registry database to ensure the ongoing stable operation of the domain.
The current operator is also not located within Somalia, and therefore similarly suffers this defect. However, the current .SO operator does not provide active registration services.
In the past, delegations have been granted to parties outside of the country where the lack of local infrastructure prohibited successful registry operation in the country. While this is still the case, it is much rarer that a country does not have the requisite infrastructure in place to ensure operations can be conducted in country - even if some elements (such as name servers) need to be geographically spread.
The applicant has made undertakings that registrations will be performed on a basis that is fair and equitable.
ICANN has received several documents in support of the Transition Federal Government’s interest in the application.
A letter from then President Abdullahi Yusuf Ahmen of the Transitional Federal Government establishes Minister Abdi Mohamed Tarrah as the relevant minister for matters relating to .SO, and the “sole person to communicate with on behalf of the Transition Federal Government of Somalia”.
Secondly, Minister Tarrah has made a declaration that the International Telecommunications Union is “authorised by the Ministry of Posts and Telecommunications to act on behalf of the Somali Administration to facilitate the redelegation of the .so ccTLD to [the ministry]”. In attachment to the declaration is a detailed Cooperative Agreement between the ITU and the Government that delineates the areas of cooperation, including .SO.
Over recent years, ICANN has been approached by many different representatives of Governments of Somalia, including different ministries. The representation under consideration by this application has the endorsement of the International Telecommunications Union, which helps bolster the claim that the agency is responsible for communications-related matters for the country.
One letter of support has been provided by the applicant representing an Internet trade organisation, but the applicant has stated that there are no viable organisations or entities that can represent the local Internet community, and that there is essentially no Internet usage in the country.
The current technical contact for .SO has stated to ICANN that they do not consent to the redelegation request. In its submission, the applicant has stated that due to the lack of current use of .SO that “an exhaustive consultation with the current operator is probably not necessary”. It is reasonable to believe there is no substantial usage of the .SO domain that would require a coordinated transfer in the event of a redelegation.
In its decision making process on accepting delegation and redelegation requests, ICANN respects the ability for a local Internet community as well as local law and local government to make decisions about the operation of a top-level domain.
In the case of .SO, the domain is presently delegated and the current operator is expressly not providing registration services within the domain. With no registration services on offer, no members of the Somalian Internet community for which .SO is designated are able to utilise the domain. Furthermore, even as a “parked” domain, it has been from time-to-time a mis-configured lame delegation with erroneous contact details listed in the IANA database. The last change made to the delegation was in 2002, and even at that time ICANN was unable to reach either the administrative and technical contacts for the domain. This change, a replacement IP address for a third-party name server, was eventually conducted at that time without hearing from the Administrative or Technical Contact after the name server operator demonstrated considerable harm in not having the change implemented.
While in practice the proposed new operation will be significantly based outside the country, there are reasonable grounds to assert connectivity and other factors prohibit a stable functioning registry that meets these requirements at this time. It is therefore reasonable to consider waiving the requirement that the domain’s operation be based locally given that the Sponsoring Organisation performing managerial oversight will be a ministry of the Transition Federal Government.
While the application to redelegation .SO does not propose a ideally constituted registry based within the country - it does represent a step forward in providing increased access to the domain for local users.
It is therefore recommended that the .SO domain should be redelegated to the Ministry of Posts and Telecommunications of the Transitional Federal Government of Somalia as per their request.
On 3 February 2009, the Board of ICANN passed the following resolution:
Whereas, the .SO top-level domain is the designated country-code for Somalia.
Whereas, ICANN has received a request for redelegation of .SO to the Ministry of Post and Telecommunications of the Transitional Federal Government of Somalia.
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.
Whereas, the ICANN Board the board is satisfied with the IANA assessment and believes that the applicant meets the relevant policy criteria.
It is hereby resolved (2009-02-03-06), that the proposed redelegation of the .SO domain to the Ministry of Post and Telecommunications of the Transitional Federal Government of Somalia is approved.
