[IRT.RegDataPolicy] Rec 28 - Implementation date - call for IRT comment completion

Tue Sep 24 20:27:58 UTC 2019

Dennis, IRT, IPT,

I agree with Roger’s points.  We won’t know for sure how long of an implementation period is needed until the policy language is complete, but at this point it’s safe to say that it will need to be at least 6 months.  Having an implementation “window” makes sense and is consistent with how other policies have been implemented.  There are a lot of variables in implementing this policy and some CPs will be able to move faster than others.

The IPT is obviously working hard on this and has covered a lot of ground.  The wave 1 analysis complete milestone (noted in the update to GNSO counsel) is a significant achievement.  Roger is right though that Feb 29th 2020 isn’t achievable and saying “unlikely to be met” doesn’t convey the right message.

I think the board scorecard on Rec 28 is also worth noting:

The Board notes that the Recommendation sets an effective date for the Policy. Given the complexity of the implementation, and the possibility of additional input on the recommendations from DPAs or other sources, there is a possibility that this date may not be met. The Board directs ICANN org to provide regular status updates of the progress of implementation and flag any potential issues or concerns with timeline so that issues can be addressed in a timely manner.

I’m not sure that there is a specific issue that is preventing the recommended timeline from being met beyond the overall size and complexity the recommendations.  Providing an update on the timing to GNSO council and the board seems in order.

Best,

Marc

From: IRT.RegDataPolicy <irt.regdatapolicy-bounces at icann.org> On Behalf Of Roger D Carney
Sent: Tuesday, September 24, 2019 1:35 PM
To: irt.regdatapolicy at icann.org
Subject: [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 28 - Implementation date - call for IRT comment completion

Good Afternoon,

Thanks Dennis and Rubens.

Dennis, I agree that when we started (and still valid today) that the implementation period will not truly be known until the policy is complete. But with what we know after working on this for the past several months, we do know that an implementation period of less than 6 months will not be possible. Along the lines of what Rubens suggests and what we have done on previous policy implementations is that there could be a variable implementation “window”. For example, CPs may implement this policy as soon as four(4) months after final publication of the Policy but are required to implement no later than eight(8) months after publication.

I think everyone knows where I stand but to specifically answer Dennis’ questions:

1.      No, February 29, 2020 is not feasible
2.      Yes, we should communicate to the GNSO, but I also think it makes sense to communicate to all SG/SO/ACs and Board.

Thanks

Roger

From: IRT.RegDataPolicy <irt.regdatapolicy-bounces at icann.org<mailto:irt.regdatapolicy-bounces at icann.org>> On Behalf Of Rubens Kuhl
Sent: Tuesday, September 24, 2019 10:18 AM
To: irt.regdatapolicy at icann.org<mailto:irt.regdatapolicy at icann.org>
Subject: Re: [IRT.RegDataPolicy] Rec 28 - Implementation date - call for IRT comment completion

Notice: This email is from an external sender.

What if we use the carrot instead of the stick ? Like establishing a required implementation for July, but incentivising CPs to deploy it sooner ?

Rubens

   Em 24 de set de 2019, à(s) 11:52:000, Dennis Chang <dennis.chang at icann.org<mailto:dennis.chang at icann.org>> escreveu:

   Dear IRT,

   I am calling on the IRT to complete comments on the Rec 29.

43

Complete Rec 29 Comments - Implementation Date<https://docs.google.com/document/d/1tjU1rkInpwb32L8Jh6uvI-EG50KmitWMe7KmeOQ_sLM/edit>

20191001

   First, I remind the IRT that when we began our work on the implementation

   we agreed that we could not commit to any implementation timeline

   until we’ve had a chance to review and analyze the recommendation.

   This has not changed.

   The important questions for the IRT now are

   1.   Recognizing that we are now 5 months away from the Feb 2020, what’s the IRT’s view on the feasibility of the 28 Feb 2020 date?
   2.   Should the view of the IRT be communicated to the GNSO Council?  Ruben’s view on this would be particularly important.

   Please note that I’ve attached Roger’s comment below for the IRT to spur the IRT discussion.

   Thanks

   Dennis Chang

   From: "IRT.RegDataPolicy" <irt.regdatapolicy-bounces at icann.org<mailto:irt.regdatapolicy-bounces at icann.org>> on behalf of Roger D Carney <rcarney at godaddy.com<mailto:rcarney at godaddy.com>>
   Date: Tuesday, September 24, 2019 at 5:51 AM

   On another scheduling issue: as I see “unlikely” mentioned below I am very concerned that my comment in Rec 28 is not being clearly understood. We are just a bit more than 5 months from Rec 28s suggested effective date of February 29th, 2020: excluding all the work Rec 27 will entail, we still have not reviewed/resolved all of the comments/questions on the proposed language of the other recommendations, we do not have a consolidated rough draft of the policy language (which I am sure will raise additional questions/comments), a public comment period of the draft language still needs to occur and from all indications there will need to be at least a six month period for implementations to align with the new policy.  As I stated in Rec 28, there is no way that this policy will become effective February 29th, 2020.

   In regards to the “unlikely” comments from the transcript and email below, I find it disheartening and not transparent at all, that this is not being communicated appropriately. I believe that we need to be clear that February 29th, 2020 is not going to happen (not that it is unlikely to happen) and that if someone is looking for a more realistic timeline then just walk back the dates (excluding Rec 27 work: at minimum 6 month implementation period, publish final policy language, public comment review/response, public comment, publish initial policy draft language, resolve initial draft questions/comments/inconsistencies, create initial draft, resolve open comments/questions on the policy language for each of the recommendations). If the Initial Policy language is published for public comment by/near ICANN-66, I believe being optimistic this works out to an effective date of July 2020 at the earliest.

   I don’t want to dwell on process or dates but I just want to be transparent with what we do know when we know it.

   Thanks

   Roger

   From: IRT.RegDataPolicy <irt.regdatapolicy-bounces at icann.org<mailto:irt.regdatapolicy-bounces at icann.org>> On Behalf Of Dennis Chang
   Sent: Monday, September 23, 2019 7:22 PM
   To: irt.regdatapolicy at icann.org<mailto:irt.regdatapolicy at icann.org>
   Subject: [IRT.RegDataPolicy] Rec 27 discussion with GNSO 20190919 - call for IRT comment completion

   Notice: This email is from an external sender.

   Dear IRT,

   Attached are the slides used to present to the GNSO Council last week.

   It should provide an easy to follow overview of the detailed workplan that was provided prior to the meeting.

   https://docs.google.com/document/d/1LNTK48adeeU_dmjSBGth04dqDdhamVKHbP5FQ4T4EI8/edit#<https://docs.google.com/document/d/1LNTK48adeeU_dmjSBGth04dqDdhamVKHbP5FQ4T4EI8/edit>

   GNSO Council seemed satisfied with the way we plan to move forward and didn’t have many follow up questions.

   One important point IRT should note was on the schedule.

Milestone

Timing

1

Wave 1 analysis complete

Week of 28 Oct 19

2

IRT review period complete

Week of 18 Nov 19

3

Wave 1 publication and delivery to GNSO

Week of 9 Dec 19

4

Wave 2 analysis complete

Week of 13 Jan 20

5

IRT review period complete

 Week of 3 Feb 20

6

Wave 2 publication and delivery to GNSO

Week of 24 Feb 20

   The Council correctly noted that ICANN org was producing a schedule that attempts to meet the 29 Feb 2020 policy effective date that the Recommendation 28 specified.

   Excerpt from transcript: “There’s clearly a tremendous amount of work to be done on this project. That date of the 29th of February 2020 is, I think, frankly unlikely to be met. But we’re trying. I think ICANN org and we as council need to be focusing on this to try to at least map out the plan for addressing these issues, understanding where we might need to initiate a new PDP, where there are other things we could do that perhaps are not a full-blown PDP to address these impacts and where there are inconsistencies or incompatibilities with old policy versus the new policy.”

   As the IRT has commented on Rec 28, the Council also acknowledges the tremendous amount of work and that the Feb 2020 date is unlikely to be met. We’ll continue our the date discussion using the Rec 28.

   FYI. ICANN org is undergoing a labor intensive research, examination, and analysis of the RegDataPolicy impacted policies and procedures. It’s important that all members of the IRT complete their review on this work plan.

   I am calling on the IRT to complete any comments you might have on Rec 27 on the workplan to handle the impacted policies and procedures.

   You will find the workplan and the attached slides in a new folder created for Rec 27 link in this new assignment as:

42

Complete Rec 27 Comments on Impacted Policies<https://drive.google.com/drive/u/0/folders/1Do8FlGUz-g5R9i30U5Q7RvPfsObQpXnl>

20191001

   Thank you for your sustained and timely support of this implementation project.

   Dennis S. Chang

   GDD Programs Director

   Phone: +1 213 293 7889

   Sykpe: dennisSchang

   www.icann.org<http://www.icann.org/> One World – One Internet

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