[gnso-gac-closed-generics] Closed Generics Preparation for 7 June Meeting
Kathy Kleiman
kathy at dnrc.tech
Tue Jun 6 22:55:28 UTC 2023
Hi Sophie,
I confess to being a bit confused. I don't see any language below that
addresses the issues raised by Greg, Alan, me, and members of the GAC.
Quick note that it is my understanding that GAC is under no obligation
to follow the SubPro Working Group's recommendation that Early Warnings
run at the same time as Reveal Day public comments, and GAC is currently
working on the timing of its Early Warnings.
I reattach our paper listing concerns, history and goals for /a
meaningful Closed Generics comment period.
/
//
Let me re-share Greg's email:
"Please respond if you can live with this compromise. If you cannot,
please offer a detailed way forward.____
__ This also misses the mark and does not provide anything close to the
result being sought by a significant portion of the group. As such, I
can't live with this either. What is needed is not merely the
possibility of the hope of the potential of an extension of the initial
"reveal day" triggered comments period. What is needed is a firm
commitment to a greater opportunity to comment -- in the form of a
second comment period for Closed Generics, to occur after GAC Early
Warnings.
The number of Closed Generics is not really relevant to whether a
second period is needed (or even the extension of the first period)
-- unless we have hundreds of Closed Generics, in which case even
more time may be needed. The issue is not primarily that commenting
organizations need time to sort through a plethora of applications;
rather, the issue is that commenting organizations will need more
time than is granted to consider whether and how to comment on the
one, two or a few Closed Generic applications that will be relevant
to it/them, to build awareness of the relevant application(s) and
get buy-in from potential participants in a comment, and then to
develop, write, circulate to what might be a substantial group of
co-authors, get back comments, revise, recirculate, and finalize the
comments. Underlying this is a belief that comments on Closed
Generics are more like to come from organizations, associations, and
groups of like-minded entities based on the very nature of the
Closed Generic gTLD. That is why this treatment is critical and why
it is sought.
Proposed revisions:
* Applications for closed generics gTLDs will be subject to the same
Public Comment period as all other gTLD applications. However, given
that closed generic gTLDs are uniquely impactful to the public
interestand to the interests of multiple entities that may identify
with a string, the group acknowledges there should be more time
dedicated to their Public Comments. The Public Comment period will
supplemented by an additional 60 daycomment period solely for closed
generic gTLD application comments, to commence upon the submission
of Early Warnings by the GAC and its members. This does not replace
ICANN’s discretion to extend the Public Comment period for all
applications, and the 60-day extension will apply to the full length
of the Public Comment period (extended or otherwise). ____
o In line with Implementation Guidance 13.6 from the New gTLD
Subsequent Procedures Final
Report<https://gnso.icann.org/sites/default/files/file/field-file-attach/final-report-newgtld-subsequent-procedures-pdp-02feb21-en.pdf>(pg.
244), this implementation should enable the public to easily
identify and obtain information about applications for closed
generic gTLDs. The group agrees that there must be a centralized
space where prospective commenters can go to understand the
rules for closed generic gTLDs and view the applications
themselves. ____
o Note: In arriving at this compromise approach to Public Comment,
the group acknowledges the unique nature inherent to closed
generic gTLDs, as well as the need for sufficient time for
meaningful Public Comments, and the public’s need to readily
find all relevant information about closed generic gTLD
applications."
Best, Kathy
On 6/6/2023 11:03 AM, Sophie Hey wrote:
>
> Hi all,
>
> I have attempted to come up with possible compromise language on
> public comments for 22.b of the Framework given the comments I saw on
> list the other day. This language attempts to take into consideration
> that feedback as well as:
>
> * SubPro
> <https://gnso.icann.org/sites/default/files/file/field-file-attach/final-report-newgtld-subsequent-procedures-pdp-02feb21-en.pdf>
> Implementation Guidance 13.6 (p 58, 244);
> * SubPro Recommendation 20.4 (p 91, 261) on 30-day operational
> public comment periods for application change requests;
> * SubPro Recommendation 28.14 (p 131, 280) on a single Public Comment;
> * SubPro Recommendation 30.5 (p 140, 283) on GAC Early Warnings
> running concurrently with the public comment period and the status
> of 30.5 as Pending in the Board’s Scorecard
> <https://www.icann.org/en/system/files/files/scorecard-subpro-pdp-board-action-16mar23-en.pdf>
> (p39) from 16 March 2023
> <https://www.icann.org/en/board-activities-and-meetings/materials/approved-resolutions-regular-meeting-of-the-icann-board-16-03-2023-en#section2.a>;
> * Operational Design Assessment
> <https://www.icann.org/en/system/files/files/subpro-oda-12dec22-en.pdf>
> section 6.2.7 (p 213) stating that the public comment period will
> run for 90-days.
>
> Proposal:
>
> 22.b Applications for closed generics gTLDs must be subject to the
> same Public Comment period as all other gTLD applications set out in
> SubPro Final Report recommendation 28.14.
>
> 1. Consistent with SubPro Recommendation 20.4, change requests to
> closed generic gTLD applications in response to public comments,
> objections, whether formal or informal, GAC Consensus Advice, GAC
> Early Warnings, or other comments from the GAC who will be subject
> to an additional 30-day operational public comment period.
> 2. In line with Implementation Guidance 13.6 from the New gTLD
> Subsequent Procedures Final Report [gnso.icann.org]
> <https://urldefense.com/v3/__https:/gnso.icann.org/sites/default/files/file/field-file-attach/final-report-newgtld-subsequent-procedures-pdp-02feb21-en.pdf__;!!PtGJab4!_6G04zuduBJlatvxO1KXVdYeKGv57RsVaOoKh3W11SOt5UF6MyWvPL2vighBwDwaI6EKwoq-W8w-Gf5bKlKhC5tZd7TIGzYhf_MMVg$>(pg.
> 244), this implementation should enable the public to easily
> identify and obtain information about applications for closed
> generic gTLDs. The group agrees that there must be a centralized
> space where prospective commenters can go to understand the rules
> for closed generic gTLDs and view the applications themselves.
> 3. Any policy work on closed generic gTLDs must consider whether any
> other public comment period for closed generic gTLDs is
> appropriate, balancing the interests of applicants who may be in
> contention sets with Closed Generics, the applicant, and
> prospective commenters.
>
> Rationales:
>
> 22.b: We can all agree that closed generics are subject to the already
> established public comment period.
>
> 22.b.i: Expressly calling out change requests for closed generic gTLD
> applications in response to public feedback requiring a separate
> public comment period. I think that changes to closed generic gTLD
> applications would already be covered by 20.4, but understanding a
> need for detail, I propose calling this out specifically.
>
> 22.b.ii: Making sure that there is outreach and information available
> to the public on closed generic gTLDs. I also did not see any push
> back to this language on list (apologies if I missed it).
>
> 22.b.iii: Committing to a policy discussion on an additional public
> comment period for closed generic gTLDs.
>
> Sophie
>
> Sophie Hey
> she/her
> Policy Advisor
> Com Laude
> *T*+44 (0) 20 7421 8250
> *Ext* 252
>
> <https://comlaude.com/>
>
> /We are pleased to launch our new YouTube channel
> <https://t-uk.xink.io/Tracking/Index/bhkAAGVfAADl_RQA0>/.
>
> *From:*gnso-gac-closed-generics
> <gnso-gac-closed-generics-bounces at icann.org> *On Behalf Of *Melissa
> Peters Allgood
> *Sent:* Tuesday, June 6, 2023 1:30 PM
> *To:* gnso-gac-closed-generics at icann.org
> *Subject:* [gnso-gac-closed-generics] Closed Generics Preparation for
> 7 June Meeting
>
> Hello all,
>
> I wanted to level-set after our call yesterday. I’ve emphasized a
> final push this week to get through your remaining work to ensure this
> group has the best opportunity possible to share a draft framework
> before the public sessions at ICANN77.
>
> At the end of our call, we discussed that staff would take inputs
> onClosed Generics Framework v4 – Edits Tracked
> <https://docs.google.com/document/d/1nEy2mQm01ITo-ovxgIVQ0kNIpLqPV4bqVxTKgZb15vQ/edit>forward.
> Staff has incorporated many of your suggestions and these are
> reflected in yellow highlight in the v4 – Edits Tracked document. A
> few comments remain in the v4 – Edits Tracked document and will be
> considered by the group on our 7 June call.
>
> To see the outcomes of your work in context, staff has compiled aDraft
> Framework for Closed Generic gTLDs
> <https://docs.google.com/document/d/1ZzjEiWbdkqOYbzoOPglwAn30qUUNRhjP8RmgKyTlgfQ/edit>thatincludes
> the edits discussed above, as well as an Executive Summary and annex
> of supporting reference material.Please note, 22.bof the Draft
> Framework for Closed Generic gTLDsis holding for the outputs of your
> red line discussion of Public Comment.
>
> Please review the Draft Framework for Closed Generic gTLDs in
> preparation for our 7 June call, as this is the complete draft
> framework, absent the Public Comment issue and a few outstanding
> points raised in the v4 – Edits Tracked document.
>
> Agenda for 7 June:
>
> 1. Complete discussion of the Public Comment red line topic
> 2. Review remaining comments in v4 – Edits Tracked
> 3. Go/No Go decision on the Draft Framework
> 4. ICANN77 Public Session planning
>
> Thank you for your continued efforts to collaborate and compromise.
>
> Melissa
>
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--
Kathy Kleiman
President, Domain Name Rights Coalition
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