I was asked for an opinion on whether an ALAC statement is necessary on the <https://community.icann.org/display/alacpolicydev/At-Large+Preliminary+Issue+Report+on+the+Inter-Registrar+Transfer+Policy+%28IRTP%29+Part+D+Workspace>Preliminary Issue Report on the Inter-Registrar Transfer Policy (IRTP) Part D. The short answer is that I do not believe that a statement is required, but I would appreciate a "sense of the ALAC" that this PDP should be initiated. IRTP-D is the last of a set of PDP's to review and possibly update various aspects of the Inter-Registrar transfer Policy (IRTP). IRTP-D consideres: a) Whether reporting requirements for registries and dispute providers should be developed, in order to make precedent and trend information available to the community and allow reference to past cases in dispute submissions; b) Whether additional provisions should be included in the TDRP (Transfer Dispute Resolution Policy) on how to handle disputes when multiple transfers have occurred; c) Whether dispute options for registrants should be developed and implemented as part of the policy (registrants currently depend on registrars to initiate a dispute on their behalf); d) Whether requirements or best practices should be put into place for registrars to make information on transfer dispute resolution options available to registrants; e) Whether existing penalties for policy violations are sufficient or if additional provisions/penalties for specific violations should be added into the policy; f) Whether the universal adoption and implementation of EPP AuthInfo codes has eliminated the need of FOAs (Forms of Authorization). This Public Comment is an opportunity to identify errors or omissions in the Preliminary Issue Report, and to provide support for initiating the PDP. O know of no specific errors or omissions. Although I support the PDP going forward, given the long history which got us to this stage, I am not expecting much opposition so I do not feel that a written comment is worth the effort. The PDP does address a number of issues that could benefit registrants and for that reason I do believe that it should go ahead. If the ALAC agrees, I would like to carry that message forward. I would also strongly advise that there be At-Large representatives on the resultant WG. Alan