Response to criticism of UIA's approach in demonstrating support

Particular criticism of the UIA approach in demonstrating support relates to the information it presented in a chart in the UIA proposal (included below) and an appendix [Appendix D] presented as a sampling of international non-profit organizations that regularly update their profile in the UIA Yearbook of International Organizations (also available on the web)

The chart below (and the Appendix from which it was extracted) indicates bodies that voluntarily respond, on a regular basis, to requests from the UIA for revision to their profiles in that Yearbook. The more extensive Appendix listing is headed "Indication of Long-term Pattern of Support for UIA Registry Activity" . Here "Registry Activity" is understood by the UIA to mean presentation of such profiles in the Yearbook.. The Appendix listing is stated to be a "Sample of 542 organizations composed of 'bodies with other international bodies as members' or 'universal organizations with members in all continents'". These 542 are effectively the beginning of a list of over 30,000 bodies -- ordered in terms of degrees of internationality -- regularly contacted to update their profiles in the Yearbook.

The UIA questions the merits of arguments based on "fig leaf" allegations and has never experienced any need to front itself with "fig leaves" [more]. The proposal text neither states nor implies that the organizations listed in the above-mentioned table and Appendix have indicated their specific support for the UIA / Diversitas bid. Nor does it claim that they were consulted in relation the bid. Rather the text argues that through their continuing collaboration with the UIA registry activity over the years, organizations such as these have indicated a concrete pattern of support for such registry activity in relation to their profiling in book, CD or web media (in fact a registry service).

Support achieved through "practice" is, in the UIA view, to be distinguished from "political" support in approval of a planned initiative -- for which formal consultation would indeed need to be undertaken. Whether or not this political support engaged the consulted organization in any new pattern of practice relevant to registry operation would be a methodological concern for ICANN.

It was further argued in the proposal (see elsewhere) that:

The UIA would like to argue that the "thick registry" activity in which it has engaged with the long-term collaboration of thousands of international bodies in practice is a demonstration of support that is far more eloquent than letters of support. "Thick registry" profiles maintained with the collaboration of members of the .org community are in this sense measures of clear support for our work.

Concern has been expressed by a large organization, by chance prominently displayed in this list, that it has been misrepresented by the UIA's mention of it in the proposal (as with the others so listed) without consultation in relation to the proposal context. The UIA wishes to make clear that these international organization names listed in the UIA proposal do indeed include those which reflect a higher degree of internationality than others which might have been listed. As is evident from the unsystematic ordering in the list, however, the items are not ordered by date, nor alphabetically, nor in any other way; those organizations that appear at the top do so only as a result of database defaults of no socio-political relevance. The ten listed in the body of the proposal were simply those at the top of the longer list assigned (due to its length) to an Appendix. Furthermore, the names of such organizations appear in many published listings of international organizations produced in reports for different purposes by a wide variety of bodies, notably for scholarly purposes. Such listings do not normally require the permission of the name-holder

The concerned organization considers the approach taken in the UIA proposal to evincing support to be misleading. This might indeed be the case if "support" is only considered to be defined in terms of some "consultation" process -- which is the only methodological approach open to bidders that do not have a pattern of relationship with .org registrants and those "across the digital divide" that may become registrants.

But the UIA proposal responds to the specific request by ICANN to "Submit any evidence that demonstrates support for your proposal among registrants in the .org TLD, particularly those actually using .org domain names for noncommercial purposes". The process of "consultation" is not specifically mentioned (whether or not it may be considered to have been implied). The UIA proposal therefore set out to demonstrate a long-term pattern of support for its registry activity amongst non-profit organizations -- notably amongst those with websites. The methodological question for ICANN is whether evidence for such support in past and continuing practice is to be considered effective support for what is envisaged in the proposal. This needs to be evaluated by ICANN against the significance for future practice of letters of support which are in no way legally binding on the bodies supplying them -- and may indeed, given the time constraints, have been produced without reference to their competent decision-making authority.

In comparing forms of endorsement for proposals, it is useful to distinguish between:

• Generic expressions of support to improve the .org community, which may be just as applicable to some other proposals;
• Character references for the organization making the proposal, unrelated to the contents of the proposal;
• Endorsement for the proposal from an authorized person within an organization without any operational commitment for its future involvement or support;
• Endorsement for the proposal from an authorized person within an organization providing competent operational commitment for its future involvement or support;
• Endorsement for the proposal from a person within an organization writing in their personal capacity only;
• Endorsement for the proposal by members of the bidding organization and therefore from particular segment of the non-commercial constituency that they represent;
• Endorsement of any of the above forms from persons who have little understanding of the internet policy issues associated with management of a TLD such as the .org domain;
• Analysis of long-term patterns of actual responsive conduct to the registry activity of the bidding organization by a large representative sample of registered non-commercial organizations.

Methodologically, the last does NOT imply any POLICY endorsement, but it does constitute legitimate evidence of future involvement in the registry in PRACTICE. This kind of analysis can only be performed by a bidder with a current registry relationship with members of the .org community. It is particularly significant in the case of bidders currently operating very thick registries and dependent on such voluntary involvement.

The UIA came into the bidding process too late to initiate an open consultation process. Its "failure" to consult with any organizations -- beyond the manner in which it "consults" them for information for its registries -- in no way means that it does not value the opinion of these organizations, nor does it imply that consultations will not be made in the future should it become the .org operator. The UIA also understands only too well that for larger organizations, with many levels of decision-makers, the correct process of consultation must be scheduled over a longer period than that available under the ICANN process.

The UIA considered doing an email / web survey of some 25,000 organizations (with email and web access) but rejected this for four reasons:

• it had just recently completed another survey on international meetings (with a response rate noted elsewhere as further concrete evidence of support "across the global internet community"); it considered that a second survey would be intrusive and insensitive to the limited resources that many organizations have to respond to such requests;
  
  
• having tracked the uptake by organizations of websites, the UIA was very aware of the abstruse nature of .org domain operation for many senior decision-makers, even amongst organizations with websites. Additionally we did not know, in terms of social survey methodology, how to construct an unbiased questionnaire for people who may well know nothing about the politi
• co-technical issues on which their support was requested -- especially if they were "beyond the digital divide";
  
  
• even though bodies with email may have websites, the technical relationship between the two applications often precludes convenient web surveys and so the result would have been biased towards those organizations with more sophisticated systems;
  
  
• concern was also felt that for support to be operationally significant rather than well-meaning; a much more complex process of interaction would have been required with the more authoritative levels of any organization consulted rather than relying on interaction with those having the necessary technical understanding of the issues.

The 15 letters of support included in the UIA proposal were from small organizations who could respond quickly to personal requests from UIA staff. They were included to exemplify the range of bodies from which such letters of support could be obtained given greater time. We are aware that a similar number of letters were also sent directly to ICANN in support of our bid. We were not aware of any criteria on which organizational support was to evaluated in terms of importance. Whether in a democratic process of consultation, the weight of some registrants is to be considered greater than others is again a matter for ICANN to decide.