[IRT.RegDataPolicy] Rec 28 - Implementation date - call for IRT comment completion
Theo Geurts CIPP/E
gtheo at xs4all.nl
Wed Sep 25 19:06:00 UTC 2019
Agreed.
Theo
Op 25-9-2019 om 14:42 schreef Luc SEUFER:
>
> Hello Marc et alia,
>
> I also believe that we should inform the Counsel that the original
> date cannot be met.
>
> Regarding the incentive, as much I like ICANN waiving its fees (or
> offering us free t-shirts), I trust there will be too many unknowns
> here. Even after its finalization, the policy will be so far reaching
> that there will be some side effects we won’t have expected. Plus,
> speaking as a registrar, we will be dependent on the registries’
> implementation.
>
> Best Wishes,
>
> Luc
>
> *From: *"IRT.RegDataPolicy" <irt.regdatapolicy-bounces at icann.org> on
> behalf of "Anderson, Marc via IRT.RegDataPolicy"
> <irt.regdatapolicy at icann.org>
> *Reply to: *"Anderson, Marc" <mcanderson at verisign.com>
> *Date: *Tuesday, 24 September 2019 at 22:28
> *To: *"irt.regdatapolicy at icann.org" <irt.regdatapolicy at icann.org>
> *Subject: *Re: [IRT.RegDataPolicy] Rec 28 - Implementation date - call
> for IRT comment completion
>
> 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 29^th 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 29^th , 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 29^th , 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 29^th , 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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