The supposed need for this policy stems from NeuStar's decision to commercialize .us à la Tonga's .to and miscellaneous other South Seas islands (albeit without the Jon Postel-sanctioned grace and foresight of Crown Prince Tupouto'a and his Two Erics, Gullichsen and Lyons). Doing so involved trashing RFC 1480, which was "based on" -- and limited delegations to "political geography."
This liberalization, of course, opened the door to a new class of would-be parvenus (usually called "squatters") -- which, in the topsy-turvy world of ICANN's Keystone Kop-style "regulation," needed to be shut pronto. Hence the torrent of new reserved names.
The problem is, where holding a delegated name under the .us hierarchy used to be fairly simple and cheap, if a bit of a hodgepodge, these new reserves impose a host of burdens and costs on hosts. For example, if you formerly held the delegation for Anytown, you now have the "opportunity" -- and with rights come responsibilities -- to hold any or all of cityofanytown.us, townofanytown.us, anytowncity.us, anytowntown.us, parishofanytown.us, and anytownparish.us, lest someone else confuse matters -- for between $152 and $395 per domain. (The low-end price doesn't actually let you use the domain: it merely prevents someone else from registering it. In less genteel circles, this might be seen as a protection racket.)
Ah, but NeuStar anticipated this problem by -- get this -- appending the two-letter state code to the domain name in order to "differentiate" them. No more anytown.ca.us: now it's anytownca.us (etc. etc.).
Did I say that was the problem? Excuse me: there's another one. Under RFC 1480, delegation was hierarchical, as noted, according to political geography. Thus, if you wanted the delegation for Anytown, California, you'd get anytown.ca.us. But NeuStar broke that taxonomy, so now everyone in every state that has an Anytown (and anyone else) can compete (read: pay) for the right to the above-mentioned litany. In the specific, this isn't especially funny for places with famously common names like Fairview, Midway, Oak Grove, Franklin, Riverside, Centerville, Mount Pleasant, Georgetown, Salem, or Greenwood; in general, it's idiotic to break a well-founded and well-implemented RFC.
It's hard to know who's responsible for this brain-dead innovation. It's tempting to blame NeuStar, but the only people who seemed to expect much from them were the ICANN functionaries who effectvely created NeuStar by approving its bid for .biz, and then, when .biz proved to be a dog, bailed them out by giving them .us.
And now, finally, for the NeuStar letter to the "usdom" list:
Subject: Reserved Names
Date: Mon, 23 Sep 2002 17:30:47 -0400
From: Casey, Jim
There has been some discussion on this list of NeuStar's state and local name reservation list and the recent publication of the registration process and price list. I wanted to take a moment to provide further background and clear up certain misconceptions.
NeuStar developed the federal, state and local name reservation list at the request of the Department of Commerce. The Department understood that once the .US domain was opened to direct second-level registrations, name speculators likely would seek to register federal, state and local names. Therefore, we worked with the Department to reserve for future registration by the appropriate parties (federal agencies and state and local governments) a set of names corresponding to these governmental entities. NeuStar used official census data to develop the state and local list. In those instances where there were multiple jurisdictions with the same name, the two letter state code was appended to differentiate the names. The "City of", "County of", etc. designators were added to avoid conflict with trademarks and/or legitimate name registrations (such as family names) by individuals and entities not associated with a state or local government.
These second-level names are not intended to replace the existing locality space. Rather, they are intended to provide federal, state and local governments with the option to register a second level name, e.g. newyorkcity.us, which they can use as they see fit. If we had not reserved these names upfront, they likely would have gone to peculators. The fee schedule for these registrations was designed to recover NeuStar's costs in conducting outreach to federal agencies and state and local governments, as well as to operate a manual registration and registrant authentication process. NeuStar agrees that the current locality space is a valuable Internet resource and is committed to maintaining and enhancing the space.
We want to clarify that the fact that we have created no new "delegated managers" since taking over administration of .US is unrelated to the reserved name list. We are prevented by the terms of our contract with the Department of Commerce from creating new delegated managers until NeuStar and the Department have completed together an analysis of the locality names and their operation. NeuStar submitted the required report at the end of April and will publish it publicly upon approval to do so by the Department of Commerce. I can assure you that, although we make several recommendations with respect to future operation of the locality names based upon the requirements of our government contract, the report is supportive and appreciative of the important and quality work of the vast majority of the existing delegated managers.
I hope that this response clears up some of the concerns raised.
Director, Policy and Business Development