IANA Report on Request for Redelegation of
the .pn Top-Level Domain
Subject: Request of the Pitcairn Island Council for
Redelegation of .pn Top-Level Domain
Date: February 11, 2000
The Internet Assigned Numbers Authority (the IANA),
as part of the administrative functions associated with management of
the domain-name system root, is responsible for receiving requests for
delegation and redelegation of top-level domains, investigating the circumstances
pertinent to those requests, and reporting on the requests. In September
1997, the IANA received a request for redelegation of the .pn (Pitcairn
Island) top-level domain. This report gives the findings and conclusions
of the IANA on its investigation of that request.
Factual and Procedural Background
On July 10, 1997, the IANA approved a request for
initial delegation of the top-level domain .pn. At that time and today,
that two-letter code was and is set forth on the ISO
3166-1 maintained by the ISO
3166 Maintenance Agency (ISO 3166/MA) <http://www.din.de/gremien/nas/nabd/iso3166ma/index.html>
as the approved Alpha-2 code for Pitcairn Island.
Pitcairn Island is an overseas territory of the United
territory is formally known as Pitcairn, Henderson, Ducie, and Oeno Islands,
due to the inclusion of some outlying islets.) The territory, located
in the South Pacific at 25º 04' S, 130º 06' W, has a total population
consisting of approximately 50 descendants of the Bounty mutineers and
their Tahitian wives. Local government of Pitcairn Island consists of
an Island Council elected mostly by the inhabitants of the island (with
a few appointed members) and an elected Island Magistrate and Chairman
of the Island Council. The UK Government appoints a Governor of the territory
and a Commissioner responsible for liaison between the Governor and the
Pitcairn Island's telephone service consists of a
local party-line telephone system. International telephone service is
limited to Inmarsat service within a daily window. The local system is
not presently capable of transmitting e-mail. The island has no airstrip.
The economy consists of subsistence farming, fishing, and handicrafts
made for sale to passing ships.
The original delegation of the .pn top-level domain
was made in the name of Tom Christian as administrative contact and Nigel
Roberts as technical contact. The listed organization was Pitcairn Names
(Orichalk Ltd). Mr Christian (the great-great-great grandson of Fletcher
Christian) is resident on Pitcairn. Mr Roberts is a private computer consultant
with an address in the Channel Islands and is associated with Orichalk
Ltd. The .pn top-level domain has been used predominantly for registration
of domain names to entities not affiliated with the territory, in exchange
for a fee collected by Orichalk.
Shortly after the initial delegation was made, on
September 8, 1997 Leon Salt, Commissioner
for Pitcairn Island, wrote to the IANA stating that:
The Government of Pitcairn Island has concluded,
after due process of examination and consultation, that the persons
who have assumed the management of the PN top-level domain, currently
registered at IANA, do not adequately serve the interests os [sic] the
country and community of Pitcairn Island.
The letter requested revocation of the delegation
to Messrs Christian and Roberts and a redelegation to the Office of the
Governor of Pitcairn Island, with nameservice to be provided by a consultant
in New Zealand.
On October 16, 1997, the IANA requested that Commissioner
Salt contact Mr Roberts to discuss and seek to resolve the situation by
On October 24, 1997, the Pitcairn Island Council met
on the island and requested the Commissioner, Leon Salt, who was then
visiting, to seek transfer of the .pn top-level domain to the Pitcairn
Island Administration (located in New Zealand). In a letter dated November
3, 1997, the Chairman of the Island Council and Chief Island Magistrate,
Jay Warren, conveyed the sentiments
of the Council to Commissioner Salt:
At our meeting held on the 24th of October 1997,
the island council has requested me to convey to you that we would like
the Pitcairn Island administration to obtain the domain name "pn"
for exclusive use in reference to Pitcairn Island. The Island Council
feels it is important to ensure the name "Pitcairn Island"
and its abbreviated form "pn" should serve the interest of
Pitcairn Island and the islanders rather than the interest of any individual
or organisation not connected with the island.
Commissioner Salt forwarded this letter to the IANA
and requested a redelegation of the .pn domain naming the Commissioner
as administrative contact.
In an e-mail to the IANA dated November 18, 1997,
Commissioner Salt stated that the original delegates were not providing
any service for the community and noted plans, under the requested redelegation,
to pr ovide Internet access to the Island by implementing a functioning
By e-mail to the IANA, Mr Roberts expressed his objection,
and conveyed Mr Christian's objection, to the redelegation. There ensued,
at Mr Roberts' behest, a series of discussions in the UK Government, and
Mr Roberts reported to the IANA in a November 23, 1997 e-mail that "the
very highest level in London" was considering whether to recommend
a course contrary to the request of the Pitcairn Island Council. A meeting
was held on January 23, 1998 among Mr Roberts and various UK Government
officials, but the UK Government continued to support the Pitcairn Island
Council's request and no resolution was achieved.
On July 21, 1998, Baroness Simons, the UK Government Minister with responsibility
for UK Overseas Territories, including Pitcairn Island, wrote to the IANA
requesting redelegation consistent with the wishes of the Pitcairn Island
Council. On July 28, 1998, Commissioner Salt reiterated the Pitcairn Island
Administration's request for redelegation. On August 3, 1998, Mr Roberts
sent the IANA another e-mail objecting to redelegation as requested by
the Pitcairn Island Council. On August 14, 1998, Dr Postel (then Director
of the IANA) wrote to Baroness Simons expressing concern that Mr Roberts
had not cooperated with the transfer that had been requested and suggesting
that she contact Mr Roberts to seek to achieve a cooperative resolution.
On September 8, 1998, Baroness Simons wrote to the
IANA expressing regret over Mr Roberts' lack of cooperation and stating
that the original delegation violated the guidelines of RFC 1591 in that
the administrative contact (Mr Christian) did not have a direct link to
the Internet. She also noted that the Island Council should have been
consulted when the delegation was made.
On September 22, 1998, the IANA advised Mr Roberts
of its belief that the redelegation would be appropriate. On September
23, 1998, Mr Roberts replied again, once again objecting. After receipt
of this letter, the redelegation was delayed. No activity occurred at
the IANA on this matter for some time, due to Dr. Postel's death on October
16, 1998, and the transition of responsibility for performing the IANA
function from the University of Southern California to the Internet Corporation
for Assigned Names and Numbers.
On September 2, 1999, Commissioner Salt forwarded
to the IANA a petition signed
by Pitcairn residents requesting the redelegation:
We, the undersigned, being residents of Pitcairn
Island, do hereby request and require that the management of our nation's
Internet Top-Level Domain (.pn.) be reassigned forthwith to the Pitcairn
Island Administration in Auckland, New Zealand, in accordance with the
Island Council's instructions of 24th October 1997 and the letter from
the Government of Pitcairn Island to IANA of September 1997.
In his accompanying e-mail, Commissioner Salt noted
that the petition had been "signed by the entire resident adult population
of Pitcairn Island (excluding other nationals), with the exception of
two members of the community. Those two are Tom Christian, who is the
present designated administrative contact, and his wife."
On September 3, 1999, Mr Roberts sent the IANA a message,
once again objecting to the redelegation that had been requested by the
Pitcairn Island Council and by the petition of the Pitcairn residents.
By a letter dated October 27, 1999, Tom Christian,
the administrative contact for the .pn top-level domain, announced his
support for the redelegation:
Following discussions with the resident community,
Island Council, Information Technology advisers, and Government of the
island, I now wish to change the delegation of the management of the
tld as detailed below.
At this time, our island does not have the telecommunications
infrastructure required for affordable Internet access for island residents.
I am satisfied, however, that under the new tld management, we will
have the best opportunity for the introduction of such infrastructure,
bringing the benefits of the Internet to the whole community here.
* * *
Please make the change to the new management with
Mr Christian accompanied his letter with a modification
template requesting redelegation as sought by the Island Council and the
On December 1, 1999, Mr Roberts sent the IANA an e-mail
that mentioned a possible compromise based on restructuring of the .pn
domain. Mr Roberts also agreed to voluntarily suspend accepting registrations
for the .pn domain.
On December 17, 1999, the IANA sent Mr Roberts an
e-mail notifying him that the IANA was investigating the request for redelegation
of the .pn top-level domain and summarizing the principal correspondence
the IANA had received on the matter. Mr Roberts was invited to submit
any additional comments he might have on the matter by December 31, 1999.
The IANA's e-mail also suggested that Mr Roberts convey his compromise
proposal directly to Commissioner Salt.
On December 27, 1999, Mr Roberts requested additional
time to respond to the December 17 e-mail. On December 30, 1999, the IANA
extended its invitation for responses until January 10, 2000, and indicated
that no further delays should be expected. On January 4, 2000, Ron Collins,
who is also affiliated with Orichalk, indicated that Mr Roberts would
no longer be involved with the .pn top-level domain at Orichalk. Mr Collins
also requested an additional extension of time (until January 31, 2000)
to respond to the December 17 IANA e-mail. No substantive response has
been received since then; instead, on January 31, 2000 Mr Collins requested
yet another extension, for thirty more days.
On January 19, 2000, the Head of the Overseas Territories
Department of the UK Foreign and Commonwealth Office wrote the IANA to
advise that he had received a compromise proposal from Mr Collins, but
that, after fully considering the proposal in good faith and with the
interests of the Internet community in mind, the Pitcairn Island Administration
(PIA) did not find the proposal acceptable. He also noted that "[t]he
PIA and the UK Government are also agreed that the Pitcairn community,
as the appropriate party, should be allowed to determine the management
and administration of .pn."
This report is being provided under the contract
for performance of the IANA function between the United States Government
and the Internet Corporation for Assigned Names and Numbers. Under that
contract, the IANA function that ICANN is responsible for performing includes:
- Administrative functions associated with root
management. This function involves facilitation and coordination of
the root zone of the domain name system. It includes . . . receiving
delegation and redelegation requests, investigating the circumstances
pertinent to those requests, and reporting on the requests. This function,
however, does not include authorizing modifications, additions, or deletions
to the root zone file or associated information that constitute delegation
or redelegation of top-level domains. The [IANA contract does] not alter
root system responsibilities defined in Amendment 11 of the Cooperative
An important component of Internet stability is adherence
to past practices in delegation and redelegation matters. Those practices
are summarized in "Internet Domain Name System Structure and Delegation"
(ICP-1), which was issued
in May 1999 to reflect "the current policies being followed by the
Internet Assigned Numbers Authority (IANA) in administering delegations
of Top Level Domain Names of the Internet Domain Names System (DNS)."
ICP-1 represents an update of the portions of RFC
1591 (which was issued in March 1994) dealing with ccTLDs, to reflect
evolution of the policies followed by the IANA through May 1999. Although
there is ongoing consideration within the ICANN process of proposals for
changes in policies concerning ccTLDs, no significant policies have yet
been adopted that are at variance with ICP-1.
A fundamental principle reflected in ICP-1 is that
ccTLDs are intended to be operated for the benefit of the Internet community
in the nation or other territory with which the country-code is associated.
As Dr Postel wrote in RFC 1591 (and as repeated
The designated manager is the trustee of the TLD
for both the nation, in the case of ccTLDs, and the global Internet
community. Concerns about "rights" and "ownership"
of domains are inappropriate. It is appropriate, however, to be concerned
about "responsibilities" and "service" to the community.
Thus, in matters of delegation and redelegation of
a ccTLD, the IANA seeks input from persons concerned or affected by the
transfer, particularly those within the nation or territory which the
ccTLD has been established to benefit. As Dr Postel observed in ccTLD
News Memo #1 and as reiterated
in ICP-1, the views of the government of the affected nation or territory
are taken very seriously in this regard. Governmental views are particularly
pertinent when the government is fulfilling its role of promoting management
of the ccTLD in the public interest.
ccTLDs have been established to facilitate and promote
the dispersion of the Internet globally. They allow the designated manager
to adapt operations of the ccTLD to best meet the economic, cultural,
and linguistic circumstances of the nation or territory involved.
In the case of a remote or developing nation or territory
that has not yet attained affordable Internet access, such as Pitcairn
Island, "proxy" DNS service outside of the nation or territory
may be appropriate "as a temporary form of assistance to the creation
of Internet connectivity in new areas." (ICP-1,
A key theme in the IANA's evaluation of redelegation
matters is that the contending parties should seek to achieve a consensual
solution to any disputes. As noted in ICP-1:
On a few occasions, the parties involved in proposed
delegations or transfers have not been able to reach an agreement and
the IANA has been required to resolve the matter. This is usually a
long drawn out process, leaving at least one party unhappy, so it is
far better when the parties can reach an agreement among themselves.
[ICP-1, section (e)]
In this matter, for over two years the contending
parties have discussed possible resolutions, but no consensual solution
has been achieved. It is apparent that this is one of those circumstances
in which non-consensual resolution is necessary.
(f) of ICP-1 discusses how redelegation
requests are to be handled:
(f) Revocation of TLD Delegation. In cases where
there is misconduct, or violation of the policies set forth in this
document and RFC 1591, or persistent, recurring problems with the proper
operation of a domain, the IANA reserves the right to revoke and to
redelegate a Top Level Domain to another manager.
Several factors appear to make the present case particularly
appropriate for redelgation:
1. All residents of Pitcairn Island,
other than the administrative contact and his wife, have signed a petition
2. The administrative contact, Tom
Christian, has separately endorsed and requested the redelegation.
3. The Pitcairn Island Council,
which is the duly constituted local government, has formally requested
the redelegation on behalf of the residents of the island.
4. The UK Government, which administers
the territory's affairs, has given its support to the request of the
Pitcairn residents and their local government.
5. The existing delegation, which
has been in place for over two years, has not resulted in the introduction
of reliable Internet connectivity on Pitcairn or in any other benefit
to the relevant community.
6. The proposed new contacts (technical
and administrative) have the technical qualifications to operate the
ccTLD, have recognized their duty to operate the ccTLD for the benefit
of the relevant community, and have put forward plans that would advance
both the development of the Internet on Pitcairn and the interests of
the Pitcairn community. These plans include (a) implementation of reliable
e-mail connectivity on the island; (b) establishment of an official
website at a .pn address to provide information to prospective tourists,
and (c) creation of a .gov.pn subdomain to support the activities of
the Pitcairn Island Administration. The operation of the .pn domain
by nonresident commercial interests in this case appears to have thwarted
these plans and is interfering with introduction of the Internet to
the Pitcairn Island community.
It is the IANA's conclusion that the .pn top-level
domain should be redelegated as requested by the Pitcairn Island Council
and the petition of Pitcairn residents.
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