Hello, Please find our position in advance of the call. NCSG has maintained a consistent position on IGO/INGO and Red Cross protections from 2012 to the present. In 2012, the NCSG Policy Committee opposed the introduction of special reserved-name protections for the IOC and Red Cross. We argued that there was no transparent legal basis for such protections, that creating them would set a precedent for endless additions to a finite list, and that any further consideration should occur through a proper Policy Development Process (PDP) in future rounds, not through ad-hoc amendments to the Applicant Guidebook. See *NCSG Policy Committee Statement on Proposal to Protect Names of the International Federation of the Red Cross and the International Olympic Committee* (23 March 2012): https://gnso.icann.org/sites/default/files/file/field-file-attach/reconvened... In 2018, when the convened IGO/INGO Working Group and Red Cross group expanded these protections to hundreds of national society names (at the second level), the NCSG reiterated its concern. Our statement recorded *“grave concern regarding the move toward reserving names and their alteration by broad interpretation of national laws and conventions in domain-name space.”* We cautioned that this practice, even if well-intentioned, undermines due process, invites unverified legal justifications, and risks turning the domain-name system into an instrument for exceptional privileges. The transcript of the GNSO Council meeting of 27 September 2018 further reflects the NCSG’s position and rationale for opposing the expansion of reserved names: https://gnso.icann.org/sites/default/files/file/field-file-attach/transcript... It is worth mentioning however that the NewgTLDs subsequent procedure did not mention any way to reserve IGOs and INGOs names. So we again ended up in a situation when PDP didn't address the issue. The current 2025 GNSO Council discussion again raises the same issue in the form “implementation options.” NCSG finds the framing of these options by the Implementation Review Team (IRT) itself problematic. The IRT’s mandate is to implement existing GNSO policy faithfully, not to present new policy directions for the Council to select from. By introducing “Option 2,” the IRT (staff) has effectively reopened a settled policy question and blurred the line between implementation and policymaking. Option 2 represents a significant expansion of protections by inserting these identifiers into the String Similarity evaluation, creating new barriers for applicants and turning reserved names into a broad blocking mechanism—something never approved through the GNSO policy process. NCSG supports Option 1 as the only correct implementation path. Option 1 is fully consistent with existing GNSO policy. It correctly ensures that the relevant identifiers are reserved solely for the corresponding entities while allowing confusingly similar strings to be handled under the standard String Similarity Review and objection procedures. This preserves the original limited intent and respects the boundaries of prior Council decisions. We also recommend that the IRT and staff revise its approach in future work. The practice of presenting “options” that include policy changes should cease, as it creates confusion, politicizes the implementation process, and risks undermining the GNSO’s policy making authority. If the IRT identifies ambiguity or disagreement about policy scope, the proper course of action is to refer the matter back to the GNSO Council for clarification, not to create new “options” that effectively rewrite or expand the underlying policy. For these reasons, NCSG supports Option 1, rejects Option 2 as a policy overreach, and urges the IRT and Staff to adhere strictly to the implementation role and avoid framing policy questions as implementation choices. Farzaneh