Apologies for missing last week’s meeting due to another commitment, but I would like to echo the sentiments of my registrar and registry colleagues that 24 hours is impossible (as many of these requests require legal review and that can be impossible on a weekend), and it could be catastrophic to wait for everything until essentially the last minute to implement. I agree another call to discuss/consider prior to ICANN77 would be helpful.

On May 16, 2023, at 11:55, Elizabeth Bacon via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> wrote:

CAUTION: This email originated from outside the organization. Do not click links unless you can confirm the sender and know the content is safe. Thanks for consolidating, Dennis!

Considering the inputs received, do you think we’ll have another call prior to ICANN to discuss the inputs everyone has submitted on the 24 hour change as well as the timeline proposal?

Thanks, Beth From: Alan Woods <alan@identity.digital> Date: Tuesday, May 16, 2023 at 6:29 AM To: Dennis Chang <dennis.chang@icann.org> Cc: Sarah Wyld <swyld@tucows.com>, Andrea Glandon via IRT.RegDataPolicy <irt.regdatapolicy@icann.org>, Elizabeth Bacon <bbacon@pir.org> Subject: Re: [Ext] RE: [IRT.RegDataPolicy] IRT Task 241 Review Implementation Timelineproposed at 10 May 2023 IRT meeting. Due 20230524

Thanks Dennis,

Apologies for chiming in on the wrong thread, and thanks for putting me on track,

Alan

Alan Woods Director, Compliance & Policy

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On Tue, May 16, 2023 at 2:05 AM Dennis Chang <dennis.chang@icann.org <mailto:dennis.chang@icann.org>> wrote: Thanks Sarah! I look forward to receiving the feedback from your implementation team.

Dear Alan and Beth, Thanks for your feedback on the timeline. I found them in another email trail realized that these should be here so I copied them over here.

From Beth Bacon: Hello All, I support Alan’s points. I do not support a mandated 30 day implementation window. A mandated 30 day window of implementation is not only a departure from standard operating procedure for implementation of a new Consensus Policy, but also introduces significant technical challenges and risk. As discussed previously, to make changes responsibly most operators will have to approach implementing their “new” data set in a phased approach. For example, first an RO might make fields optional, then in a second phase they would stop accepting certain fields, and finally they would simply not offer certain fields. This allows Rys and Rrs to make a large change in manageable phases reducing the risk of complications in any one phase. I believe this would also be complicated for ICANN compliance. If all parties are making changes at the same time it could be overwhelming. However, if there is a phased approach, operators and compliance can work together to find a way that supports Compliance’s needs as well as operators’. It’s also important to note that this agreement on 18 month implementation has been in place since discussions around the Temporary Specification and operators have already begun their planning around that timeline. Finally, it’s standard procedure to allow for implementation of a Consensus Policy up to and including the final implementation date to allow for exactly the flexibility described above. I’m happy to chat further on this and to arrange to have one of our tech folks join a call and chat as well. Many thanks, Beth

From Alan Woods: Dear Dennis, Catching up on the threads on this, I am happy to chime in on the email. The arrangements to be put in place for compliance with the Registration Data Policy are complex. Registry operators shall need to ensure that we have adequate time to not only develop, but test and implement/launch system updates to address the expected changes. We also must ensure we engage in clear and collaborative efforts with registrar partners to minimize, to the greatest extent possible, the impact of implementation to them and their operations. It would be our sincere hope that implementation expectations would remain as per usual, i.e. that the contracted parties may implement the policy at any time post the publication of the final policy, but no later than the last date for implementation. This will ensure and support a coordinated, phased and frankly a more stable implementation, for the benefit of all parties and the broader DNS. We also would like to remind that this path to implementation is required in the Interim Registration Data Policy. The current policy clearly notes that “During this stage, the contracted parties may implement either the Interim Policy or the Registration Data Policy in its entirety, or elements of both, as they prepare for the effective date of the Registration Data Policy document.” This was specifically inserted to provide flexibility to contracted parties, so as to ensure a measured and careful implementation period between publication of the policy and the final implementation date, acknowledging the likely complexity of this endeavor. Warmest regards, Alan

Thanks everyone for you feedback on timeline. Please reply to this email for your input on the timeline. 241 Review Implementation Timeline proposed at IRT meeting on 10 Mat 2023 <x-msg://19/#m_-7927625043947869031_m_76943500794680> 20230524

Thanks, Dennis Chang

From: Sarah Wyld <swyld@tucows.com <mailto:swyld@tucows.com>> Date: Thursday, May 11, 2023 at 5:43 AM To: Dennis Chang <dennis.chang@icann.org <mailto:dennis.chang@icann.org>> Subject: [Ext] RE: [IRT.RegDataPolicy] IRT Task 241 Review Implementation Timelineproposed at 10 May 2023 IRT meeting. Due 20230524

Thanks Dennis! I will be able to discuss this with our internal implementation team next week and then provide feedback before the May 24 deadline.

-- Sarah Wyld, CIPP/E

Policy & Privacy Manager Pronouns: she/they

swyld@tucows.com <mailto:swyld@tucows.com>

From: Dennis Chang via IRT.RegDataPolicy <mailto:irt.regdatapolicy@icann.org> Sent: May 10, 2023 7:19 PM To: Sarah Wyld via IRT.RegDataPolicy <mailto:irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] IRT Task 241 Review Implementation Timelineproposed at 10 May 2023 IRT meeting. Due 20230524

Dear IRT,

Please review and provide your input on the implementation timeline presented at the IRT meeting today. 241 Review Implementation Timeline proposed at IRT meeting on 10 Mat 2023 <x-msg://19/#m_-7927625043947869031_m_76943500794680> 20230524

To be clear, this is a departure from our original plan that provides several advantages and benefits, further outlined below.. We request your feedback after you’ve had a chance to discuss this approach with your technical implementation team.

The timeline can be found in the IRT workbook under the tab called “Timeline.” [docs.google.com] <https://protect-us.mimecast.com/s/_-7fCXD2y5HOn8jCV9HKg?domain=urldefense.co...> 241 Review Implementation Timeline proposed at IRT meeting on 10 May 2023 20230524

The key dates to the timeline include:

Publication of the Registration Data Policy on 1 August 2023 Preparation: implementation development, coordination, testing for transition from 1 August 2023 to 1 August 2025 (2 yrs) - Stage 1 of Interim Registration Data Policy for gTLDs <https://protect-us.mimecast.com/s/pvXgCYENz5SA3nmU9q9vq?domain=icann.org>. Enact Implementation Plan: Transition / cutover period from 1 August 2025 to 29 August 2025. (Stage 2 of ​​Interim Registration Data Policy for gTLDs <https://protect-us.mimecast.com/s/pvXgCYENz5SA3nmU9q9vq?domain=icann.org>): may begin to implement measures consistent with the Registration Data Policy and/or Interim Registration Data Policy for gTLDs. Policy Effective date on 30 August 2025. (Stage 3 of Interim Registration Data Policy for gTLDs <https://protect-us.mimecast.com/s/pvXgCYENz5SA3nmU9q9vq?domain=icann.org>): all parties have implemented measures consistent with the Registration Data Policy.

Rationale for this timeline: Follow the Policy Change Calendar <https://protect-us.mimecast.com/s/esE4CZ6NA0iQMkAfy532W?domain=icann.org>using the February and August cycle for major releases. Provide a minimum 18 months to prepare for implementation as requested by CPH. Provides all implementers adequate time to coordinate and collaborate to be prepared to transition from the interim policy to the permanent policy. Account for RDAP implementation timeline where the effective date of the Registration Data policy comes after the WHOIS Sunset date (Feb 2025.) This avoids development of WHOIS for those who plan to Sunset WHOIS, thus saving resources for all involved. Minimize the transition period where the Interim and Registration Data Policies are both being used to 1 month (from 18 months in prior plan). This provides more predictability for a global transition from the Interim to the Permanent policy. An efficient way to make the transition that also reduces risks of confusion for RDDS users and disconnect between Registries and Registrars. The short-term transition period aligns better with the “Flag Day” concept typically used in the technical community primarily responsible for implementing.

The policy language to represent this timeline would be: This Policy is effective on 30 August 2025. The Interim Registration Data Policy for gTLDs will remain in effect until 29 August 2025. During the period of 1 August 2025 through 29 August 2025, Registry and Registrar may continue to implement measures consistent with the Interim Registration Data for gTLDs or this policy in its entirety, or elements of both.

Please feel free to reply with suggestions to the policy language (Section 4) that matches your input.

As always, I am grateful for your support through the end here. We are almost there. Let’s continue our excellent collaborative ways to finish this together.

Kind Regards, Dennis S. Chang GDD Programs Director Phone: +1 213 293 7889 Sykpe: dennisSchang www.icann.org <https://protect-us.mimecast.com/s/8mdYC1wP04sqpPxiYMxCM?domain=icann.org> One World – One Internet

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