Bill,
The Registry is the party that must revert the data to the previous state. For the stability of the Internet, it must be done as quickly as possible before old correct caches time out. Therefore, that's where the penalties should apply.
Agree. This is a solution to the publication problem, and putting my hat <wicked_expired_{g,cc}tld_registry="on>, I can say that acting in lieu of a temporarily or permanently defunct registrar is normal, as is mark-up by hand of zonefiles, post-production but pre-publication. At <insert worthless {g,cc}tld operator here> I used to say all the time, "We are the registrar of last resort, when things go awry, we go acorn or asquash [1]."
(2) a 4 hour standard of promptness for all Registrars, starting from initial notice of any kind. That gives them enough time to:
Here's where it gets crappy. The gTLDs are in Reston, Reston, Toronto, Toronto and Reston, Reston and New York. The latter three have little or no facilities-based names, and are out of scope. The registrars are in more than 18 timezones, and may be fictional. In fact, for malfeasence, the bad actors are likely to be resellers, not registrars, or what Bob Connolley refers to as "phantom registrars". When we started working EPP the universe of writers (the cred problem) was 70. Last week's mail from ICANN is that they expect that 60 more registrars will be accredited within the next 60 days, which is a drop off from the growth in the number of registrars over the past year. Turn to http://www.iana.org/assignments/registrar-ids and check it every so often (does anyone have dated snapshots? I want same, TiA), the integer identifier is a lot closer to 1k than 1c. Why non-linear growth in the number of registrars three years after the bottom dropped out of the market? The drop market. There is speculation that applications have been prepared in bulk. These are the "phantom registrars". The bottom has fallen out of the secondary market too. Independent of the utility or morality of the secondary market, and my registrar makes pin money in that market, there are hundreds more write access tokens to the VGRS dbms than there was two, or four years ago. In the quasi-contractual world of ICANN agreements, which everyone is ready to wave threateningly at any registrar for lack of due diligence over what amounts to less than the price of a bottle of Chilean wine, there is the equal access clause. That clause means that all of the accredited registrars, including the "phantom registrars", are in your risk universe. They all have read|write creds, and some have very, very little technical staffing, or involvement. You wrote off-list during this mess to someone at a business that offers parties that have gotten ICANN papers an outsourced operations and hosting solution, "no hands but marketing". The current chair of the registrar constituency offers "registrar in a M$ can" solutions to new registrars. As the saying goes in ICANN registrar and registry policy debates, ICANN has no business determining business models. The skill and clue level for a significant set of the registrar universe is difficult to underestimate. So, with that sleet on the city workers, every hour of every day a "phantom registrar" is going "dark" for at least 18 hours, if not longer, and that assumes that the "phantom registrar" of the hour keeps "business hours". With that in mind, would you like to try and restate the temporal properties of registrar function, where unlike the prior regime, a registrar could decline to ack a xfr request and become a loosing registrar, a gaining registrar can now decline to ack a post-xfr request to re-instate, for 18 hours plus weekends and holidays. In passing, it is possible that for the "phantom registrar" class of business models, the penalty of de-accreditation is overstated. Eric [1] Its an Indian joke. There were two of us. That's wicked rare in the network rackets. We told jokes.