Below and attached is the ICANN Business Constituency (BC) comment on the Initial Report on the Third ccNSO Policy Development Process (ccPDP3): Retirement of ccTLDs. On the question of expediting ccNSO decisions on the recommended policy for the Retirement of country code Top-Level Domains (ccTLDs), by separating Part 1 (on the Retirement of ccTLDs) from Part 2 (on Review Mechanism), the BC supports separating the two policy development efforts. The ccTLD Review Mechanism designed to appeal the decision of a IFO who refuses a request for extension of a ccTLD Manager should be independent of the Retirement policy. The BC is therefore aligned with the proposal from the Retirement and Review Working Groups that the two efforts could follow their own course. Regarding the question; if there are any major concerns with respect to the proposed recommendation for the retirement policy, which have not been raised before or are inadequately addressed in the final paper, the BC reiterates its desire for a process that is not in conflict with the ICANN contractual agreement applicable to Registries and expects this policy to also cover both IDN and ASCII ccTLDs. As we said in our previous comment on the proposed policy for the Retirement of ccTLDs, the BC would like to see a mechanism that: 1. Stipulates the process for preserving and archiving relevant data from the Retiring ccTD for historic basis by ICANN/ccNSO. 1. At the least, mandates a periodic review of ISO 3166-1 Maintenance Agency (“ISO 3166/MA”) standard which drives the decision of the IFO to initiate and coordinate the Retirement of ccTLDs. -- This comment was drafted by Lawrence Olawale-Roberts. It was approved in accord with the BC Charter. Steve DelBianco Vice chair for policy coordination ICANN Business Constituency