[IRT.RegDataPolicy] IRT Task 241 Review Implementation Timelineproposed at 10 May 2023 IRT meeting. Due 20230524

Sarah Wyld swyld at tucows.com
Thu May 18 13:34:45 UTC 2023

Hello all,

I cannot support this suggested August 2025 30-day implementation window plan and strongly advocate for returning to the 18-month buffer period that has been the expectation throughout this IRT’s time together. 

>From a technical perspective, holding all changes to be released industry-wide over a 1-month period is extremely dangerous. There will be a huge amount of changes to coordinate across registries, registrars, and reseller channels, and trying to release all those updates and fix any resulting bugs (across literally thousands of contracted parties and TLDs) is just asking for us to all DDOS ourselves. 

Each provider in this industry needs to be able to make updates on a schedule that works for them internally, and as Beth explained we need to ensure there’s plenty of time for upstream changes to happen before downstream changes tie in, which is not accommodated as part of this suggested path. 

>From a policy perspective, as Alan W. said, I’m not certain that the Interim Registration Data Policy allows for the proposed new path. 

Finally, we all know there has been significant attention to this policy process and the extended time period that it’s taken for us to finish the work and get a new policy in place. We should allow contracted parties to start implementing and coming into compliance with the new requirements as soon as possible instead of artificially inserting a two-year delay that benefits no-one and is not being requested by anyone. 

I’m happy to discuss further, and can bring a tech person to the call if that would help. Will we meet again to address this before ICANN77?

Thank you, 

Sarah Wyld, CIPP/E

Policy & Privacy Manager
Pronouns: she/they

swyld at tucows.com 

From: Dennis Chang via IRT.RegDataPolicy
Sent: May 10, 2023 7:19 PM
To: Sarah Wyld via IRT.RegDataPolicy
Subject: [IRT.RegDataPolicy] IRT Task 241 Review Implementation Timelineproposed at 10 May 2023 IRT meeting. Due 20230524

Dear IRT,
Please review and provide your input on the implementation timeline presented at the IRT meeting today. 
Review Implementation Timeline proposed at IRT meeting on 10 Mat 2023
To be clear, this is a departure from our original plan that provides several advantages and benefits, further outlined below..  We request your feedback after you’ve had a chance to discuss this approach with your technical implementation team.

The timeline can be found in the IRT workbook under the tab called “Timeline.”
Review Implementation Timeline proposed at IRT meeting on 10 May 2023
The key dates to the timeline include:
1. Publication of the Registration Data Policy on 1 August 2023
2. Preparation: implementation development, coordination, testing for transition from 1 August 2023 to 1 August 2025 (2 yrs) - Stage 1 of Interim Registration Data Policy for gTLDs.
3. Enact Implementation Plan: Transition / cutover period from 1 August 2025 to 29 August 2025. (Stage 2 of ​​Interim Registration Data Policy for gTLDs): may begin to implement measures consistent with the Registration Data Policy and/or Interim Registration Data Policy for gTLDs. 
4. Policy Effective date on 30 August 2025. (Stage 3 of Interim Registration Data Policy for gTLDs): all parties have implemented measures consistent with the Registration Data Policy. 
Rationale for this timeline:
1. Follow the Policy Change Calendar using the February and August cycle for major releases.
2. Provide a minimum 18 months to prepare for implementation as requested by CPH.  Provides all implementers adequate time to coordinate and collaborate to be prepared to transition from the interim policy to the permanent policy.
3. Account for RDAP implementation timeline where the effective date of the Registration Data policy comes after the WHOIS Sunset date (Feb 2025.) This avoids development of WHOIS for those who plan to Sunset WHOIS, thus saving resources for all involved. 
4. Minimize the transition period where the Interim and Registration Data Policies are both being used to 1 month (from 18 months in prior plan).  This provides more predictability for a global transition from the Interim to the Permanent policy. An efficient way to make the transition that also reduces risks of confusion for RDDS users and disconnect between Registries and Registrars.  
5. The short-term transition period aligns better with the “Flag Day” concept typically used in the technical community primarily responsible for implementing.

The policy language to represent this timeline would be: 
This Policy is effective on 30 August 2025. The Interim Registration Data Policy for gTLDs will remain in effect until 29 August 2025. During the period of 1 August 2025 through 29 August 2025, Registry and Registrar may continue to implement measures consistent with the Interim Registration Data for gTLDs or this policy in its entirety, or elements of both. 

Please feel free to reply with suggestions to the policy language (Section 4) that matches your input. 

As always, I am grateful for your support through the end here.  We are almost there.  
Let’s continue our excellent collaborative ways to finish this together.

Kind Regards,
Dennis S. Chang
GDD Programs Director
Phone: +1 213 293 7889
Sykpe: dennisSchang
www.icann.org  One World – One Internet

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