Hi Sarah,

Thank you for supporting the full review of the public comment and sharing your thoughts.

IPT has just completed the initial review of all comments and sorted out some comments that require further in-depth consideration. After the ICANN meeting, we plan to resume our work for careful evaluation for potential impact to the policy implementation requirement. As you may know, we are also supporting other projects. With the recent board activities and direction, many of us are conflicted and we are managing to get this done as quickly as we can without rushing through them.

Following are my answers to the questions regarding the Implementation Plan.

I don’t think I’ve discussed it with the IRT yet. At the CP Summit, I mentioned the need for such a plan and called for us to work together. I wrote to the IRT late January that I’ll be gathering information via individual consultations with those implementers that volunteered. My plan is to convene an IRT meeting to share what I’ve learned and ask for input.

There isn’t a standard for the implementation plan. The plan depends on the policy. I use this process when the implementation is complex and interdependent to facilitate efficient and effective implementation for all. I view Registration Data Policy as an implementation that could benefit from a collaborative implementation plan.

I’ll be providing the guidelines and processes as the lead for this implementation project. I don’t plan on a mandatory plan since we’ve not presented our draft policy language for public comment that way. It would be more of a model implementation approach suggested for your use.

The implementation plan should cover key implementation task along our 18 month timeline. I expect that we could establish a few milestones to track our progress together. The plan should consider all changes and you are correct that the same timing/compliance requirement applies to Registration Data Policy as well as the other affected policies. This will be a topic for IRT when I am ready to present a baseline plan for your consideration.

Thanks

Dennis Chang

From: Sarah Wyld <swyld@tucows.com>
Date: Wednesday, March 8, 2023 at 06:01
To: Dennis Chang <dennis.chang@icann.org>, "Andrea Glandon via IRT.RegDataPolicy" <irt.regdatapolicy@icann.org>
Subject: [Ext] RE: [IRT.RegDataPolicy] ICANN76 IRT Session - cancelled

Hi Dennis,

Thanks for sending out this explanation. I was surprised to see the session cancelled, as I know we all want to conclude this work and get started on implementing the Policy.

I’m of course in support of fully reviewing all feedback from the public comment period. Does the IPT have a target date for when the review will be completed? It’s already been more than six weeks since the report was issued.

I was surprised to read that you are working on an “implementation plan”. I had expected that once the final round of comments were reviewed and addressed that the Policy would be published and that registrars and registries are then expected to comply within 18 months of that publication date.

The questions that come to mind for me are:

Was this implementation plan discussed while the IRT was meeting regularly? I don’t remember hearing about it until now.
Is an implementation plan a standard part of any Policy outcome? I’m not familiar with anything similar from the 2016 Transfer Policy, which is the most comparable (in scale) policy change I can think of this morning.
What are the guidelines and processes for creating this implementation plan? Will it be a mandatory plan that all registrars and registries must follow when implementing the new Policy?
What does this implementation plan cover? Is it about how a registrar/registry implements the new Registration Data Policy, or does it relate to the other affected policies which are being updated as per Rec 27 from EPDP Phase 1? I thought all the policy changes have the same timing/compliance requirements.

Thanks,

--

Sarah Wyld, CIPP/E

Policy & Privacy Manager

Pronouns: she/they

swyld@tucows.com

From: Dennis Chang via IRT.RegDataPolicy
Sent: March 6, 2023 5:20 PM
To: Andrea Glandon via IRT.RegDataPolicy
Subject: [IRT.RegDataPolicy] ICANN76 IRT Session - cancelled

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