July 19, 2001

The Honorable Donald L. Evans
Secretary of Commerce
U.S. Department of Commerce
1401 Constitution Avenue, NW
Washington, DC 20230

Dear Secretary Evans:

As the Co-Chairs of the U.S. Public Policy Committee of the Association for Computing Machinery (USACM), we are writing to share our concerns regarding the Department of Commerce's Request for Quotation (RFQ) [SB1335-01-Q-0740] for services to establish centralized management and coordination of .US top-level domain (usTLD). In our opinion, the RFQ incorporates the Internet community and American public's interest in the usTLD so inadequately that it should be rescinded and reissued with revised requirements. While we recognize the Department's current agreement for operation of the usTLD expires in November of this year, we are concerned that closing the RFQ period later this month as currently planned does not provide sufficient time to support an open and full public discussion on the future management of the usTLD. Used almost exclusively for state and local governments, schools, and libraries, the usTLD is a public-owned commodity that is rightfully regarded by the Internet community as a national treasure. Accordingly, the Department should be as diligent in transferring the usTLD as it is in the transfer of similar telecommunications resources, such as the allocation of spectrum for new advanced wireless services. Unfortunately, the Department's RFQ does not reflect the U.S. Internet community's high regard for usTLD.

The RFQ seems to be based on a desire for administrative continuity rather than to build a secure policy foundation for the future use of the usTLD. By issuing the RFQ in this manner, the Department has unintentionally limited opportunities for informed consideration of this proposal. Policy requirements of the RFQ that merit more discussion with the Internet community include its:

In summary, the Department has not completed a careful and complete evaluation of the public policy requirements for the current and future management of the usTLD sufficient to meet the diverse needs of the U.S. Internet community. Considering the Department plans to close the RFQ period on July 27, 2001, we respectfully request the Department rescind or revise the RFQ at this time. At a minimum, the process should be delayed until confirmation of and review by Ms. Nancy Victory, the Administration's designee to head the Department's National Telecommunication and Information Administration.

The Association for Computing Machinery, an educational and scientific computing society with over 75,000 members, represents a large and influential block of Internet-users in the United States. The USACM is pleased to offer our technical expertise to the development of technology policy. We have designated as contacts Jeff Grove at (202) 659-9711 and Kathryn Kleiman at (202) 842-2345 to assist your staff in achieving needed improvements in the solicitation.


Barbara Simons, Ph.D.
Eugene H. Spafford, Ph.D.
Co-Chairs U.S. ACM Public Policy Committee (USACM) Association for Computing Machinery