A month ago, ICANN announced that it had a large set of proposed changes to its “Guidelines for the Implementation of Internationalized Domain Names”. The original guidelines are fairly confusing and not widely deployed by the ccTLDs, so one would think that the proposed revisions would be clearer and more useful.

No such luck. Instead of describing what the problems with the old guidelines were, the committee that put together the new proposal simply added a whole bunch more rules. Note that there was never any written notice that the new guidelines were being considered. Thus, when they asked the community to comment on their new proposal, they were hit with a wide variety of criticism.

Bret Fausett and I posted a message listing our five major concerns. In brief:

1. The proposal would benefit greatly from a statement of purpose
2. The proposal is titled “Guidelines,” but it contains many statements about what a registry must and must not do
3. Version 1 of the guidelines has been in existence for two years, but ICANN has not published a report on the successes and failures in version 1
4. The proposed revisions do not have a list of the changes between versions and why each was made
5. The proposal includes a mandatory obligation on TLD registries to participate in a loose and undefined “collaboration” with other entities

In other words, lots of new rules with no apparent enforceability, and no explanation about what the purpose is or why the previous rules were not good enough.

The result of this effort would not have been so bad if the parties had been more open about what they were doing. Instead, it was created by a subcommittee of a committee that doesn’t appear to exist, at least from searching the ICANN web pages. It was created without asking the IETF for input, and thus resulting in the message from the IAB that points out a serious technical flaw. The group also didn’t ask the Unicode Consortium for input, even though that group knows more about internationalization than anyone else, thus resulting in a message from them pointing out even more errors in the proposal.

On the other hand, since it is phenomenally unlikely that these rules will ever be enforced, the fact that the are confused and technically flawed may not be all that important. What is important is that ICANN has, yet again, failed to follow its own guidelines about openness, about limiting its scope of control, and about working with outside bodies. And yet, folks like Bret still think that ICANN would be better than a take-over by the UN; I remain unconvinced.