Date: 15 July 2019 The ccNSO Council welcomes the opportunity to comment on the process proposal for streamlining organisational reviews[1]. Please note that comments from the ccNSO Council do not reflect the views of the ccNSO as a whole, nor of individual ccNSO members. Need for, scope, and purpose of the organisational reviews should be the primary focus of the discussion. The ccNSO Council believes that, although important, most topics and questions raised in the paper are secondary. Before addressing other issues, the need, scope and desired outcomes of organisational reviews should be fully discussed. Organisational reviews were introduced in 2002 (following the Evolution and Reform Process). Although ICANN structures have become established and are constantly refining their internal operations and procedures, the need and concepts developed for Organisational Reviews in 2002 do not reflect the current role of the SO/ACs as part of the Empowered Community. The review model and topics to be addressed fail to take into account the evolved ICANN model, including the role of SO/ACs as Decisional Participants of the Empowered Community. To illustrate this point: Section 4.4 of the 2016 ICANN Bylaws states: "The goal of the review, ., shall be to determine (i) whether that organization, council or committee has a continuing purpose in the ICANN structure, ..". This is identical to the text of Article IV section 4.1 of the 2014 ICANN Bylaws. Currently, all three SOs and two of the ACs have been designated as Decisional Participants and are members of the Empowered Community. In the view of the ccNSO Council, it is not up to an Independent Reviewer, acting under the guidance of ICANN Board and Org, to answer the question whether a Decisional Participant has a continuing purpose. We also believe that now it is the right time to reflect on the nature of Supporting Organisations and Advisory Committees as entities to be reviewed: these are entities through which the "volunteers" are organised as part of the multi-stakeholder model. As a result, the culture and structure of each SO/AC are very specific and have evolved over the years to meet specific operational needs of the communities they represent. We should take into account that the vast majority of the volunteers participating in the ccNSO do so because of their work within their ccTLD. Based on our experience with the ccNSO membership, we would expect a broader view on the costs in the streamlining paper, an element that we do not see in the proposal. Such a view should take into account not only costs related to ICANN Org but also costs of any volunteer during the entire review process. It is necessary to understand and have an informed discussion about the community fatigue. The role of community members in any review processes should be well-defined so that the possible impact of any choice is known upfront. For example, the paper identifies an issue related to the (limited) pool of Independent Reviewers, one of the concerns raised being the level of their knowledge (or lack thereof). At the ccNSO Council level we experienced that even with an open-minded and fair reviewer, it takes quite some effort to bring them up to speed and - more importantly - to ensure that during the review process an adequate level of knowledge and historic background is maintained. Given the limited time volunteers of some communities can spend on ICANN and SO/AC related matters, reviews might not be a top priority for them. Organisational reviews are perceived as a (unnecessary) burden, distracting from the primary reasons why volunteers participate in ICANN. On behalf of the ccNSO Council Katrina Sataki Chair _____ [1] https://www.icann.org/en/system/files/files/streamlining-org-reviews-proposa l-30apr19-en.pdf