Hi Owen,

I see a little confusion and I’ll try to clear it up here.  

My discussion with the implementers is to gain understanding of the implementation from their perspective.  It’s the same conversation I had with you and Essie that Cyrus hosted.   It does not delay implementing a policy but helps in that implementation.  Not all are as well aware of our policy implementation as you are.  Therefore, it will be our job to make them aware so no one is surprised.  To facilitate the understanding of this policy implementation, IPT is currently working on an educational material that could be used by the implementers to communicate with their counterparts in their organization.  I’ll bring this to the IRT for feedback before we provide it to the community in general.

I haven’t heard of any significant concerns but there is a recognition that this policy will introduce potential divergent paths for implementation.  The interdependent nature of this policy implementation requires much cooperation among the implementers.  What’s important at the moment is the evaluation of the public comments.  As you know, there is a significant number of public comments that need to be evaluated for potential impact of the policy implementation requirements. 

There are implementers that are non-CPH.  Data Escrow Agents and EBERO Service providers  are  examples. I’ve not had a chance to speak to them yet but planned to after ICANN76.  I’ll share my findings with the IRT when I ask for your input on a  proposed approach for collaborative implementation.

Thanks

Dennis Chang

From: "IRT.RegDataPolicy" <irt.regdatapolicy-bounces@icann.org> on behalf of "Owen Smigelski via IRT.RegDataPolicy" <irt.regdatapolicy@icann.org>
Reply-To: Owen Smigelski <owen.smigelski@namecheap.com>
Date: Monday, March 6, 2023 at 16:47
To: "Andrea Glandon via IRT.RegDataPolicy" <irt.regdatapolicy@icann.org>
Subject: Re: [IRT.RegDataPolicy] ICANN76 IRT Session - cancelled

Hi Dennis,

Thanks for the update, however I am a little confused. 

You mention that you are following up with implementers but it’s not clear how that can delay implementing a policy. It was my assumption that the parties implementing this (registrars and registries) are well aware of the requirements, and ICANN provides an effective date that we then all comply with. 

Are there any significant concerns raised by registrars and registries regarding the implementation of this policy? If there are, then I think this is something for the IRT to consider. Nothing in the policy should be a surprise to contracted parties- this has been under discussion/consideration for almost 5 years now, and EPDP Phase 1 Final Report was approved by the ICANN Board in May 2019. 

If the implementers you are referring to are non-CPH, can you please provide some additional information regarding the nature of these concerns? I think this should be something the full IRT considers. 

Regards,

Owen

On Mar 6, 2023, at 14:20, Dennis Chang via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> wrote:

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Dear IRT,

I asked Andrea to cancel the IRT session at ICANN76 that had been scheduled for 16 March 2023.

I had planned to coordinate and collaborate to build our 18-month implementation plan at the session.  However, I don’t think we’ll be ready to have that discussion just yet.

As you know, we’ve received a large number of public comments requiring review and consideration.  IPT is currently going over each and every comment for potential impact on the implementation requirement and the policy language.  I’d also like to conduct a few more interviews with the implementers to gain insights to build a proposed baseline plan after the ICANN76.

I expect that Registration Data policy implementation could be a subject of some of the sessions you are attending; please share any outcome with the IRT when you note them.

To those traveling this week to Cancun, I wish you a pleasant and safe journey. Unfortunately, I won’t be able to join you this time but you’ll see me fully participating remotely.  Please feel free to chat me up or call me along the way.

-- 

Kind Regards,

Dennis S. Chang

GDD Programs Director

Phone: +1 213 293 7889

Sykpe: dennisSchang

www.icann.org One World – One Internet

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