Re: [At-Large] [ALAC-Announce] ICANN News Alert -- Public Comment Invited: Proposal for the Use of Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Strings
Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Registries. Good evening: I do not support this proposal. If these new gTLD are subject to such risks of egregious malpractice that even the industries that they are supposed to serve do not support them, let alone their regulatory agencies and governments, then these 'strings' should not be delegated at all. The proposed Policy Advisory Boards are clearly a palliative for a wider issue that has not yet been addressed: By constituting such ICANN-esque global regulatory agencies in each of the sectors concerned, ICANN would expose itself to unprecedented obligations and liabilities which it is in no position to discharge, world-wide. There is no reference to the real costs of the Policy Advisory Boards, their autonomy, authority and their recourse in the event of disputes. To be meaningful in any sense, these PABs would require full-time professional positions. The original proposal refers to the PABs being financed exclusively by the Registry concerned, which is manifestly absurd. They would have to be financed directly by ICANN, to ensure a minimum of independence. The original proposal envisages a small PAB (12-18 members) for each Registry, representing eleven or more categories of interest groups, world-wide, not including governments. The internal inconsistency of the proposal is self-evident. The proposed text sets the bar for compliance excessively low. Here we have the PAB ensuring that the Registry does not operate in a manner that is “... antithetical to the overriding goals of competition and innovation.” Nothing more? Consequently, it would appear to be inconsistent with the public interest to pursue “the further development of the PAB model” until the eventual Registries themselves propose credible and viable global solutions to the issues that have been identified. Regards Christopher Wilkinson On 22 Mar 2014, at 02:59, ICANN At-Large Staff <staff@atlarge.icann.org> wrote:
[http://www.icann.org/images/gradlogo_bow.jpg]<http://www.icann.org/> News Alert
http://www.icann.org/en/news/announcements/announcement-21mar14-en.htm
________________________________ Public Comment Invited: Proposal for the Use of Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Strings
21 March 2014
Forum Announcement: Comment Period Opens on Date: 21 March 2014 Categories/Tags:
* Top-Level Domains * Contracted Party Agreements
Purpose (Brief): The purpose of this public comment period is to obtain feedback and collect broader community input into the further development of the PAB model, and to which TLD strings it may best apply. Public Comment Box Link: http://www.icann.org/en/news/public-comment/pab-new-gtld-strings-21mar14-en....
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On 22 Mar 2014, at 19:35, Christopher Wilkinson <cw@christopherwilkinson.eu> wrote:
Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Registries.
Good evening:
I do not support this proposal. If these new gTLD are subject to such risks of egregious malpractice that even the industries that they are supposed to serve do not support them, let alone their regulatory agencies and governments, then these 'strings' should not be delegated at all.
The proposed Policy Advisory Boards are clearly a palliative for a wider issue that has not yet been addressed:
1. By constituting such ICANN-esque global regulatory agencies in each of the sectors concerned, ICANN would expose itself to unprecedented obligations and liabilities which it is in no position to discharge, world-wide.
2. There is no reference to the real costs of the Policy Advisory Boards, their autonomy, authority and their recourse in the event of disputes.
To be meaningful in any sense, these PABs would require full-time professional positions. The original proposal refers to the PABs being financed exclusively by the Registry concerned, which is manifestly absurd.
They would have to be financed directly by ICANN, to ensure a minimum of independence.
3. The original proposal envisages a small PAB (12-18 members) for each Registry, representing eleven or more categories of interest groups, world-wide, not including governments. The internal inconsistency of the proposal is self-evident.
4. The proposed text sets the bar for compliance excessively low. Here we have the PAB ensuring that the Registry does not operate in a manner that is “... antithetical to the overriding goals of competition and innovation.” Nothing more?
Consequently, it would appear to be inconsistent with the public interest to pursue “the further development of the PAB model” until the eventual Registries themselves propose credible and viable global solutions to the issues that have been identified.
Regards
Christopher Wilkinson
PS: The At Large mail server succeeded in deleting all the formatting from my original message, rendering it almost illegible. So I am resending the original text. Apologies for double posting. CW
On 22 Mar 2014, at 02:59, ICANN At-Large Staff <staff@atlarge.icann.org> wrote:
[http://www.icann.org/images/gradlogo_bow.jpg]<http://www.icann.org/> News Alert
http://www.icann.org/en/news/announcements/announcement-21mar14-en.htm
________________________________ Public Comment Invited: Proposal for the Use of Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Strings
21 March 2014
Forum Announcement: Comment Period Opens on Date: 21 March 2014 Categories/Tags:
* Top-Level Domains * Contracted Party Agreements
Purpose (Brief): The purpose of this public comment period is to obtain feedback and collect broader community input into the further development of the PAB model, and to which TLD strings it may best apply. Public Comment Box Link: http://www.icann.org/en/news/public-comment/pab-new-gtld-strings-21mar14-en....
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At-Large Official Site: http://www.atlarge.icann.org
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At-Large Official Site: http://atlarge.icann.org
Hi Chris, While I am a supporter in general of PABs (as in the case of the PIR/.org Registry for example) I'm not sure that mandating their use is a great idea. Even if I thought it was, the wording of this proposal is very troublesome. Just to give one example: "Policy Advisory Board applicants who are not accepted due to numerical limitations shall have an opportunity to rotate on to the Policy Advisory Board as others rotate off at appropriate intervals," This means that anyone who applies gets to be seated on a PAB (eventually). I doubt that the folks from .gay (for instance) would be happy to have a virulent homophobe on their PAB, but that's what this would allow (if .gay were a highly regulated string, which it isn't, but I think you get my gist). It would also allow domainers to get on PABs and weaken eligibilty requirements just so they could speculate in the names of those strings. You raise some excellent points below, many that i hadn't thought of previously. Thanks, McTim On Sat, Mar 22, 2014 at 2:48 PM, Christopher Wilkinson <cw@christopherwilkinson.eu> wrote:
On 22 Mar 2014, at 19:35, Christopher Wilkinson <cw@christopherwilkinson.eu> wrote:
Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Registries.
Good evening:
I do not support this proposal. If these new gTLD are subject to such risks of egregious malpractice that even the industries that they are supposed to serve do not support them, let alone their regulatory agencies and governments, then these 'strings' should not be delegated at all.
The proposed Policy Advisory Boards are clearly a palliative for a wider issue that has not yet been addressed:
1. By constituting such ICANN-esque global regulatory agencies in each of the sectors concerned, ICANN would expose itself to unprecedented obligations and liabilities which it is in no position to discharge, world-wide.
2. There is no reference to the real costs of the Policy Advisory Boards, their autonomy, authority and their recourse in the event of disputes.
To be meaningful in any sense, these PABs would require full-time professional positions. The original proposal refers to the PABs being financed exclusively by the Registry concerned, which is manifestly absurd.
They would have to be financed directly by ICANN, to ensure a minimum of independence.
3. The original proposal envisages a small PAB (12-18 members) for each Registry, representing eleven or more categories of interest groups, world-wide, not including governments. The internal inconsistency of the proposal is self-evident.
4. The proposed text sets the bar for compliance excessively low. Here we have the PAB ensuring that the Registry does not operate in a manner that is "... antithetical to the overriding goals of competition and innovation." Nothing more?
Consequently, it would appear to be inconsistent with the public interest to pursue "the further development of the PAB model" until the eventual Registries themselves propose credible and viable global solutions to the issues that have been identified.
Regards
Christopher Wilkinson
PS: The At Large mail server succeeded in deleting all the formatting from my original message, rendering it almost illegible. So I am resending the original text. Apologies for double posting. CW
On 22 Mar 2014, at 02:59, ICANN At-Large Staff <staff@atlarge.icann.org> wrote:
[http://www.icann.org/images/gradlogo_bow.jpg]<http://www.icann.org/> News Alert
http://www.icann.org/en/news/announcements/announcement-21mar14-en.htm
________________________________ Public Comment Invited: Proposal for the Use of Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Strings
21 March 2014
Forum Announcement: Comment Period Opens on Date: 21 March 2014 Categories/Tags:
* Top-Level Domains * Contracted Party Agreements
Purpose (Brief): The purpose of this public comment period is to obtain feedback and collect broader community input into the further development of the PAB model, and to which TLD strings it may best apply. Public Comment Box Link: http://www.icann.org/en/news/public-comment/pab-new-gtld-strings-21mar14-en....
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At-Large Official Site: http://atlarge.icann.org
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Christopher +1. This illustrates one of the dangers of industry or business self-regulation. The measures proposed would compound the fundamental problem, not solve it. Jean-Jacques. ----- Original Message ----- From: "Christopher Wilkinson" <cw@christopherwilkinson.eu> To: "ICANN At-Large Staff" <staff@atlarge.icann.org>, "At-Large Worldwide" <at-large@atlarge-lists.icann.org> Sent: Dimanche 23 Mars 2014 02:35:35 Subject: Re: [At-Large] [ALAC-Announce] ICANN News Alert -- Public Comment Invited: Proposal for the Use of Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Strings Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Registries. Good evening: I do not support this proposal. If these new gTLD are subject to such risks of egregious malpractice that even the industries that they are supposed to serve do not support them, let alone their regulatory agencies and governments, then these 'strings' should not be delegated at all. The proposed Policy Advisory Boards are clearly a palliative for a wider issue that has not yet been addressed: By constituting such ICANN-esque global regulatory agencies in each of the sectors concerned, ICANN would expose itself to unprecedented obligations and liabilities which it is in no position to discharge, world-wide. There is no reference to the real costs of the Policy Advisory Boards, their autonomy, authority and their recourse in the event of disputes. To be meaningful in any sense, these PABs would require full-time professional positions. The original proposal refers to the PABs being financed exclusively by the Registry concerned, which is manifestly absurd. They would have to be financed directly by ICANN, to ensure a minimum of independence. The original proposal envisages a small PAB (12-18 members) for each Registry, representing eleven or more categories of interest groups, world-wide, not including governments. The internal inconsistency of the proposal is self-evident. The proposed text sets the bar for compliance excessively low. Here we have the PAB ensuring that the Registry does not operate in a manner that is “... antithetical to the overriding goals of competition and innovation.” Nothing more? Consequently, it would appear to be inconsistent with the public interest to pursue “the further development of the PAB model” until the eventual Registries themselves propose credible and viable global solutions to the issues that have been identified. Regards Christopher Wilkinson On 22 Mar 2014, at 02:59, ICANN At-Large Staff <staff@atlarge.icann.org> wrote:
[http://www.icann.org/images/gradlogo_bow.jpg]<http://www.icann.org/> News Alert
http://www.icann.org/en/news/announcements/announcement-21mar14-en.htm
________________________________ Public Comment Invited: Proposal for the Use of Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Strings
21 March 2014
Forum Announcement: Comment Period Opens on Date: 21 March 2014 Categories/Tags:
* Top-Level Domains * Contracted Party Agreements
Purpose (Brief): The purpose of this public comment period is to obtain feedback and collect broader community input into the further development of the PAB model, and to which TLD strings it may best apply. Public Comment Box Link: http://www.icann.org/en/news/public-comment/pab-new-gtld-strings-21mar14-en....
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participants (3)
-
Christopher Wilkinson -
McTim -
Subrenat, Jean-Jacques