[Gnso-newgtld-wg-wt4] Registry Services straw-person

Rubens Kuhl rubensk at nic.br
Fri Sep 1 02:52:37 UTC 2017

> On Aug 31, 2017, at 9:49 PM, Alan Greenberg <alan.greenberg at mcgill.ca> wrote:
> Rubens, what GNSO Policy are you referring to? The only one I am aware of is the RSEP.

This one:

https://gnso.icann.org/en/issues/registry-services/final-rpt-registry-approval-10july05.htm (GNSO Policy as approved by Council)
https://gnso.icann.org/en/meetings/review-process-registry-change-requests25apr05.pdf (Process flowchart as approved by Council)
https://www.icann.org/resources/board-material/resolutions-2005-11-08-en (Board resolution approving GNSO Registry Services Policy)
https://www.icann.org/resources/unthemed-pages/net-registry-agreement-2005-07-01-en (.NET agreement of the time, mentioned in Board Resolution)

While RSEP is indeed its nickname, it was born as "Procedure for use by ICANN in considering requests for consent and related contractual amendments to allow changes in the architecture or operation of a gTLD registry".

> Although public consultation is not specified in the policy, the implementation of the policy publishes the RSEP requests and has included an opportunity for public input during the 15 day evaluation process.

If the current implementation is right or wrong is terms of following the policy is something for ICANN staff to argue. The implementation has been updated quite heavily over the years, without any community input, so both the policy and the policy implementation framework might not have been observed. Sticking to GNSO and Board approved policy helps us not go into down into this discussion.

What I can assure you than ICANN does not treat that 15-day interval as a capital P capital C capital P Public Comment Period. I have once questioned that in one RSEP request I filed in 2014 (RSEP 2014082, 2-char SLDs release), and they were pretty clear in not considering that 15-day as such.

On a curious note,  even ICANN does not know who receives the e-mails for registryservice at icann.org , which is the channel for the providing comments during that 15-day period:
(In fact it's a comment forum with more forum spam than actual comments)

What could be aligned with policy is for ICANN to take public input on the decision of whether a registry service creates a security, stability or competition concern. There is no other criteria in the policy to be assessed for a registry service, so if someone is willing to help ICANN making its mind on these 3 topics, I think it's only fair to help them, as long as ICANN follows the policy-specified deadlines (15 days for the initial determination, 45 days after determination for competition concerns) and investigates only the subject matters above.


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