Nominet are again consulting on their idea to introduce .uk domain registration. But the proposals are little better than before.
Nominet's new .uk proposals, described in more detail on their website, include:
Nominet are effectively arguing that they will make a lot more money through these proposals, and this is good because they will then be able to do more of their work improving the trust and security of the .uk namespace. I'm paraphrasing Nominet's argument. (See Leslie Cowley's blog on the Nominet website for more on the thinking behind the changes).
However, they make little or no case for this. There are no details about how much they expect the proposals to raise, or how they plan to use the extra money to improve trust and security in the .uk namespace.
Haven't we been here before?
This is the second consultation Nominet have run on this idea. The first was at the end of last year. They received lots of negative feedback last time. We responded and were critical of the proposals, and recommended they be dropped. We argued that the plans would lead to:
1. the creation of a 'walled garden' that would undermine confidence in the rest of the UK domain space including .co.uk
2. the imposition of additional cost burdens on website operators, which are likely to be particularly significant for SMEs
3. the positioning of Nominet in an inappropriate role, by setting them up as arbiters of trust online and giving them additional and somewhat unchecked powers. This would effectively create for Nominet a monopoly over 'trust' and security in the UK domain space.
What has changed from the last consultation?
Not a whole lot. Two main things:
Why do Nominet think this is a good idea?
The shortest answer: because they will make an awful lot of money from it. Nominet say this proposal will 'keep the namespace competitive', and that the namespace needs to 'develop and innovate to remain competitive and relevant.' Further on in the consultation document Nominet specify four benefits:
We have serious doubts about whether the proposals for greater verification of registrants' details will have any effect on consumer confidence. For example, it seems like it will still be fairly easy for somebody to simply register using a 'real' name and address that is not theirs. Nominet certainly provide no evidence of the likely effects of the new process.
The key argument Nominet make seems to be this: the commercial development of Nominet is a good thing because it will enable them to do more to make the .uk domain space more trusted and secure. I asked Nominet about this on Twitter:
@peterbradwell: @Nominet thanks! is the idea that nominet's commercial growth via new .uk sales will improve nominet's ability to meet its public purpose?
@Nominet: @peterbradwell yes or at least help us to maintain the ability in the face of the changing domain name landscape.
The lack of a justification for the .uk proposals
Figures, estimates or otherwise, of the costs and benefits of the proposals are absent from the consultation document or background paper. There is no estimate of the extra income this will generate for Nominet or the registrars, and no estimation of the costs to businesses. There are no proposals for exactly what Nominet will do with the extra money to further their public purpose work. Nominet say there is no reason to provide a business case.
All of this makes it hard if not impossible to consider whether this is the best way to improve the trust and security of the .uk namespace. The relationship between Nominet's continued commercial growth and improvements in trust and security of .uk namespace seems to be taken as given.
The WebMastering.co.uk blog estimates Nominet could make upwards of £25m from the proposals - doubling their revenue - and lists a number of important questions that have not been addressed.
Nominet's .uk plans still represent an effort to exploit their position to create new online 'real estate'. We're currently putting together our formal response to Nominet, which we'll post on the website as soon as possible.
More detail on the consultation and information on how you can respond are on the Nominet site.