Dear RDRS Standing Committee, It is the U.S. position that the RDRS should be maintained and enhanced. An improved RDRS will help address the needs of requestor communities. In addition, the GAC has expressed support for developing the RDRS into a more permanent system with various enhancements. Therefore, we cannot support the text from the below message being included in the Standing Committee’s report. In addition, I support Gabe Andrews's comments on this topic in the report and the alternate text he proposed. I also agree it is important to read Recommendation #14.2 in its entirety. Owen Fletcher U.S. Alternate Representative to the ICANN Governmental Advisory Committee (GAC) National Telecommunications and Information Administration (NTIA) U.S. Department of Commerce ________________________________ From: Sarah Wyld via Gnso-rdrs-sc <gnso-rdrs-sc@icann.org> Sent: Friday, June 27, 2025 3:42 PM To: gnso-rdrs-sc@icann.org <gnso-rdrs-sc@icann.org> Subject: [Gnso-rdrs-sc] RDRS SC Report - Financial Sustainability Hello Standing Committee, I have drafted some suggested text to add to Chapter 4 of our report which discusses the EPDP Phase 2 recommendation on Financial Sustainability and the RDRS's costs and value. I will drop the text into the document but since I think some of us prefer email I wanted to share it here as well. I hope this is helpful and look forward to discussing all our comments as we finalize the report. Thank you. Considerations regarding financial sustainability As the purpose of the RDRS pilot project is to gather data to further inform the Operational Design Assessment’s consideration of costs of building and operating the SSAD, the RDRS SC discussed Recommendation #14 and the RDRS costs (see Chapter 3 Lessons Learned). These costs should be considered in relation to (a) the value provided to requestors, (b) the value provided to (and costs incurred by) participating registrars, and (c) any costs incurred by registrants. Value to requestors can be measured in terms of volume of requests and in feedback from requestors about their experiences with the service. Request volume has dropped over the term of the pilot project. Requestors have indicated generally low opinion of the RDRS (see Chapter 1 “Outcomes and Satisfaction” and “Likelihood of Continued Use”). Value to registrars can be measured in terms of the volume of participating registrars and in feedback from registrars about their experiences with the service. Registrar participation has dropped over the course of the pilot project. Registrars have also indicated a generally low opinion (see Chapter 1 “System Usability and Experience”, “Outcomes and Satisfaction”, and “Likelihood of Continued Use”.) The current operational funding of RDRS is provided by ICANN, so the true source of funding is domain owners themselves—the registration fees paid to registrars that fund ICANN are being used to fund the disclosure of registrants’ private data. As such, all RDRS costs are ultimately borne by domain owner data subjects themselves, directly contradicting the goal stated in Recommendation #14: 14.2. The objective is that the SSAD is financially self-sufficient without causing any additional fees for registrants. Data subjects MUST NOT bear the costs for having data disclosed to third parties; Requestors of the SSAD data should primarily bear the costs of maintaining this system. Furthermore, Data Subjects MUST NOT bear the costs of processing of data disclosure requests, which have been denied by Contracted Parties following evaluation of the requests submitted by SSAD users. ICANN MAY contribute to the (partial) covering of costs for maintaining the Central Gateway. For clarity, the EPDP Team understands that registrants are ultimately the source of much of ICANN’s revenue. The Standing Committee acknowledges the value of a lightweight system to standardize the disclosure request process and distribute requests to registrars, as well as the potential value of the possible enhancements discussed for the RDRS. Considering the general satisfaction levels indicated by RDRS users (both requestors and registrars) and the significant ongoing operational costs (not to mention the initial costs of building the system), the Standing Committee does not believe that the value presented is of such benefit that ICANN should continue funding this service. If the RDRS is to continue or any successor system is to be created, it must adhere to the consensus reached in Recommendation #14 relating to Financial Sustainability. -- Sarah Wyld, CIPP/E Pronouns: she/they Head, Policy & Privacy Tucows #MakingTheInternetBetter swyld@tucows.com<mailto:swyld@tucows.com> Responses to this email are processed according to the Tucows Privacy Policy<https://www.tucows.com/privacy>