[council] Communication from Registration Data Policy IRT

Rubens Kuhl rubensk at nic.br
Wed Oct 2 19:34:55 UTC 2019

As council liaison to the Registration Data Policy IRT, the one formed to implement EPDP Phase 1 recommendations, I am relaying this as requested by the IRT.

The main message  is that  29 Feb 2020 recommended date was deemed to not be feasible due to not providing adequate time for IRT to complete a full review and analysis.

The reasons for that include:
- Large Scope of work: 29 recommendations; 40+ impacted policies and procedures
- Data matrix for 60+ data elements completed for all transactions for both registrars and registry operators
- Several recommendations require in-depth IRT discussions as there are multiple interpretations
- IRT needs to fully understand the implications and not rush a policy that has such a wide impact

The current situation is:
- All 29 recommendations analysis formulated and are under IRT review
- Initial draft policy language for each recommendations have been proposed for IRT review
- Policy language for scope and terms have been drafted
- Initial FAQ document drafted

When asked for a new date estimate, the IRT view is that:
- Estimate can’t be done until after review and analysis
- Implementation timeline estimate will be available after IRT have the whole draft
- Estimated date will be published for the public comment

In summary, the IRT ask is to give them the time they need to do the job.

My personal note on that ask is that it looks reasonable, and since this policy includes the so-called "rainbow bridge" that allows contracted parties to move faster if they are ready while allowing more time for those that need it, the average implementation date will be sooner than the policy required date.


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