Should Telnic be allowed to let people register their phone numbers as .tel domain names?

That's the question ICANN is currently posing to the internet-using public, after it determined that allowing numeric-only .tel domains does not pose a security and stability threat.

If you can register a phone number in almost every other gTLD (except VeriSign's .name), then why not in .tel? On the face of it, it's a no-brainer.

But Telnic's request represents a huge U-turn, reversing a position it has held for 10 years, that runs the risk of drawing the attention of the International Telecommunications Union.

Telnic originally applied for .tel during ICANN's very first new gTLD round, back in 2000.

The third-party evaluator ICANN hired to review the new TLD applications clearly assumed that .tel domains would be mainly text-based, noting that Telnic, unlike other .tel bids:

does not make use of phone numbers in the sub-domain name, but instead uses names to designate the intended destination of VoIP calls… the Telnic application appears to have the least impact on PSTN numbering.

The report added, parenthetically: "It should be noted that Telnic's application does not explicitly renounce the future use of numbers".

That all changed after November 2000, when the ITU wrote to ICANN to express concerns about the four proposed telephony-related TLDs:

it is the view of ITU that it would be premature for ICANN to grant any E.164-related TLD application as this may jeopardize these cooperative activities or prejudice future DNS IP Telephony addressing requirements.

E.164 is the international telephone numbering plan, which the ITU oversees. It also forms the basis of the ENUM protocol, which stores phone numbers in the DNS under e164.arpa.

ICANN's board of directors used the ITU letter to reject all four telephony TLDs, which irked Telnic. The would-be registry filed a Reconsideration Request in an attempt to get the decision reversed.

In it, Telnic attempted to persuade ICANN that the ITU had nothing to worry about with its "text-based" and strictly non-numeric TLD. The company wrote (my emphasis):

* All-digit strings will be permanently embargoed.

* Broad terms and conditions and safeguards will be implemented covering any abuses that could possibly lead to any PSTN confusion, conflict or similarity.

* Measured use of numbers might be permissible where there is no direct, marginal, implied or similar confusions/conflicts with PSTN codes or numbers – and where digits form an incidental part of a text string (e.g. johnsmith11.tel).

ICANN's reconsideration committee denied the request.

In 2004, when ICANN's sponsored TLD round opened up, Telnic applied for .tel again. This time, it was careful to avoid upsetting the ITU from the very outset.

Indeed, the second paragraph of its application stated clearly:

Digits are to be restricted to maintain the integrity of a letters/words based top-level domain and to avoid interference with established or future national and international telephone numbering plans.

The application referred to the namespace as "text-based" throughout, and even used the need for policies regulating the use of digits to justify the sponsoring organization it intended to create.

The application stated:

The .Tel will not:

…

Allow numeric-only domains to be registered, and therefore will not conflict with any national or international telephone numbering plan.

It also said:

Domain name strings containing only digits with or without a dash (e.g. 08001234567, 0-800-1234567) will be restricted and reserved to maintain the integrity as a letters/words based top-level domain

Despite these assurances, it was obvious that the ITU's concerns about numeric .tel domains continued to bother ICANN right up until it finally approved .tel in 2006.

During the board meeting at which Telnic's contract was approved, director Raimundo Beca pressed for the inclusion of language that addressed the constraints on numeric domains and chair Vint Cerf asked general counsel John Jeffrey to amend the resolution accordingly.

While that amendment appears to have never been made, it was clearly envisaged at the moment of the board vote that .tel was to steer clear of numeric-only domains.

Telnic's contract now specifically excludes such registrations.

Given all this history, one might now argue that Telnic's request to lift these restrictions is kind of a Big Deal.

A Telnic spokesperson tells me that, among other things, the current restrictions unfairly exclude companies that brand themselves with their phone numbers, such as 118-118 in the UK.

He added that Telnic request has been made now in part because VeriSign has requested the lifting of similar restrictions in .name, which ICANN has also concluded is not a stability problem.

However, as far as I can tell .name was not subject to the same kinds of ITU-related concerns as .tel when it was approved in 2000.

Telnic proposes one safeguard against conflict with E.164, in that it will not allow the registration of single-digit domains, reducing the potential for confusion with ENUM strings, which separate each digit with a dot.

If the ITU does rear its head in response to the current .tel public comment period, it will come at a awkward time, politically. Some ITU members have said recently they want the ITU to form a committee that would have veto power over ICANN's decisions.

But Telnic says, in its proposal, that it does not know of anybody who is likely to object to its request.

Perhaps it is correct.