The Internet Assigned Numbers Authority (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 relevant to those requests, and reporting on the requests.
This report gives the findings and conclusions of the IANA on its investigation of a request for redelegation of .MA, the country-code top-level domain (ccTLD) for Morocco.
Factual and Procedural Background
Morocco is a North African country with a population of over 33 million people. It borders Algeria and Western Sahara, and has coastlines on both the Atlantic Ocean and Mediterranean Sea. The country is assigned the ISO 3166-1 alpha-2 code of “MA”.
On 3 June 1992, IANA approved a request for the delegation of the .MA ccTLD. The assigned administrative and technical contact was Amine Mounier Alaoui of Ecole Mohammadia d'Ingenieurs. The Ecole Mohammadia d'Ingenieurs (EMI) is listed as the Supporting Organisation.
In 1995, the technical management of .MA was taken over by the national telephone provider, presently known as Itissalat Al Maghrib (IAM, literally Morocco Telecom). They continue this role today, whilst EMI plays no active role in the day-to-day management of .MA.
In the intervening period, IANA has conducted a number of routine changes to the nameserver data for .MA at the administrative/technical contact’s request, most recently in August 2005.
In February 2005, Agence Nationale de Régementation des Télécommunications (ANRT), the national telecommunications regulator, launched an online consultation on the management of the .MA domain. The questions posed in the consultation covered the present management of .MA, the advantages of the current operator, the difficulties experienced with .MA, and both the short-term and long-term visions for .MA management.
ANRT summarised the main criticisms of the present .MA administration, as expressed in the submissions to the consultation, as: a lack of transparent rules and procedures; an absence of WHOIS service to obtain registrant details; the lack of reseller channels; the inability to appeal the registration of a domain; an absence of procedure to modify an existing registration; and a lack of neutrality having the dominant stakeholder in the telecom market operating the domain registry.
In November 2005, ANRT organised an Internet conference that received over 500 participants. These participants represented telecommunications providers, ISPs, the government, the private sector, and civil society. The discussion of .MA management was said to be a key theme for the meeting, with a number of speakers supporting action in line with the result of the online consultation.
On 12 May 2006, a redelegation request was lodged with IANA. It seeks the delegation of .MA to be transferred to ANRT. It is proposed that the Director General of ANRT be listed as both the administrative and technical contact for the domain. The present Director General of ANRT is Mohamed Benchaaboun.
IANA received a letter from the Moroccan Minister of Economic and General Affairs, Rachid Talbi El Alami, approving to the redelegation of .MA to ANRT. The letter notes “some weakness in the management of the Moroccan top level domain” and that the government “believe that [ANRT] is an appropriate entity for the redelegation of the management and administration of [.MA]”.
Amine Mounir Alaoui, the current Administrative and Technical Contact, assented to the redelegation to ANRT, commenting that “ANRT recognises that the Internet naming system is a public resource in the sense that its functions must be administered in the public or common interest”.
In response to the initial request and supporting documents, IANA enquired on the transition plan for moving operations from the current operator to the new operator.
IANA also requested further information on the 2005 community consultation project, to which ANRT responded by providing specific details on the consultation and the responses.
IANA’s analysis of the community sentiment to the operation .MA noted that there was a weight of opinion that sought to have its operation vested in a not-for-profit organisation. IANA expressed concern to ANRT that the community outreach that the request for private sector led management did not align with the nature of the redelegation request.
In response, ANRT said that the government is being proactive to the underlying management concerns, and will ultimately transition to private sector management:
Given that the [local Internet] community has not started anything to resolve the actual management problems and improve the situation, ANRT responded positively to several requests to be the one to organise the community. […] Once the whole .ma reform process is done […], ANRT will invite the community of .ma users and assist it in establishing a not for profit entity that will take over the management of the .ma, in the manner of what is being done in other countries.
(Translated from the original French language document)
ANRT reiterated that it is constantly solicited by members of the local Internet community on .MA’s management problems, and the organisation felt it was pressing to address the issue.
On 18 July 2006 the ICANN Board of Directors considered the request, and authorized the President of ICANN to move forward with the delegation of the .MA top-level domain to ANRT.
As part of the redelegation process, IANA seeks to assess the community sentiment for or against the redelegation request.
Direct endorsements of the redelegation to ANRT were received from Association des Professionnels des Technologies de L'information (APEBI), and the Moroccan chapter of ISOC — Moroccan Internet Society.
The applicant provided IANA with details of the public consultation process they conducted in 2005. As noted, the analysis showed a cross-section of opinion, which predominantly was critical of the current operation, and provided views on how to proceed. IANA’s analysis was that the community sentiment was aligned with the request, apart from the structure of the new supporting organisation. IANA sought clarification which resulted in an undertaking to further migrate operations toward private sector management.
IANA has received no communications in opposition to the change. Given the de facto operator of the domain is not the listed IANA contacts that are required to give consent under root zone management procedure, IANA specifically sought clarification from ANRT that IAM supported the request.
They responded that they will have an operational agreement with IAM for the interim period that will see IAM continue operating the registry until such time as ANRT has completed its policy review. At that stage, a call for tenders will be announced to identify a specialised operator that will operate the registry under the new rules.
This report is being provided under 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 ccTLDs, investigating the circumstances pertinent to those requests, and issuing a report documenting IANA’s findings.
In its role as investigator of delegation requests, IANA is guided by the practices summarized in:
“Domain Name System Structure and Delegation” (RFC 1591). This document describes the practices relating to delegations at its publication in 1994.
“Internet Domain Name System Structure and Delegation” (ICP-1). This document represents an ICANN-written update of the portions of RFC 1591 dealing with ccTLDs and reflects subsequent evolution of the policies followed by the IANA through May, 1999.
“The Governmental Advisory Committee 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 of a ccTLD, IANA seeks input from both the requesting party as well as from persons and/or organizations that may be significantly affected by the change in the top-level DNS hierarchy, particularly those within the nation or territory the ccTLD designates. 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 three documents into consideration, the evaluation of a delegation request involves determining facts that relate to the applicant’s capacity to meet the following criteria:
Operational and technical skills
- The prospective manager has the requisite skills to operate the TLD appropriately. (ICP-1 §a, RFC 1591 §3.5)
- There must be reliable, full-time IP connectivity to the nameservers and electronic mail connectivity to the operators; (ICP-1 §a; RFC 1591 §3.1)
- The manager must perform its duties in assigning domains and operating nameservers with technical competence (ICP-1 §d; RFC 1591 §3.5)
Operator in country
- The prospective manager supervises and operates the domain name from within the country represented by the TLD; (ICP-1 §a; RFC 1591 §3.1)
- The prospective administrative contact must reside in the country represented by the TLD. (ICP-1 §a; RFC 1591 §3.1)
- The prospective manager must be equitable and fair to all groups encompassed by the TLD that may request domain names (ICP-1 §c; RFC 1591 §3.3)
- The prospective manager has the requisite authority to operate the TLD appropriately, with the desire of the government taken very seriously. (ICP-1 §a, GAC Principles)
- Significantly interest parties in the domain should agree that the prospective manager is the appropriate party to receive the delegation (ICP-1 §a; RFC 1591 §3.4)
Pertaining to the obligations described above, IANA believes that applicant has reasonably demonstrated a redelegation would be appropriate. In more detail, the applicant’s credentials as they relate to the enumerated criteria are:
Operational and technical skills.
ANRT has demonstrated a suitable interest in the policy and administrative aspects of operating .MA, and seems to have the engagement of various parties in the local Internet community. In the short term, operation will continue with the current registry operator, and ANRT will call for tenders to operate the registry function once domain policy has been revised.
Operator in country.
The supporting organisation is the Moroccan telecommunications regulator, with the administrative contact as the Director General of that organisation.
The applicant has made undertakings to IANA that registrations will be performed on a first-come first-served basis that is fair and equitable.
The ICANN Government Advisory Committee Principles observes that the Internet’s naming system is “a public resource … administered in the public or common interest.” In general, ICANN’s GAC recognizes that each government has the ultimate responsibility within its territory for its national public policy objectives, however in the case of a redelegation, this may be tempered by ICANN’s responsibility to ensure the Internet DNS continues to provide an effective and interoperable global naming system.
The Government has been the initiator of the request, and actively supports the reassignment. The Supporting Organisation is proposed to be an arm of the government, with day-to-day operation outsourced to a competent registry operator.
Based upon investigations and research, IANA believes the applicant has predominantly met the basic criteria to support the redelegation request.
According to RFC 1591 and ICP-1, IANA needs to respect the ability for a local Internet community as well as local law and local government to make decisions about the operation of a TLD.
Through research, IANA has concluded this is a good faith exercise to introduce more accountability to the operation of .MA, that helps bring the management more in line with community views. The current operator does not contest the redelegation, and the community has expressed support for the change.
IANA therefore recommends that the .MA domain be redelegated to Agence Nationale de Régementation des Télécommunications of Morocco as per their request.