Re: [bc-gnso] FOR FINAL APPROVAL: draft BC comment on proposed final 2013 RAA (Registrar Accreditation Agreement)

[Stéphane Van Gelder <stephvg@xxxxxxxxx>]

Steve, Elisa and Anjali,

Thanks for this work.

SVGC supports this redraft.

Best,

Stéphane

Envoyé de mon iPhone4

Le 29 mai 2013 à 04:26, Steve DelBianco <sdelbianco@xxxxxxxxxxxxx> a écrit :

> On the 22-May BC member call we discussed final changes to the BC comment 
> draft, to address whether registrars would be obligated to sign an updated 
> RAA.   
> 
> Anjali Hansen and Elisa Cooper updated the draft with this paragraph (on page 
> 2):
> 
> Section 5.3 -- “Right to Substitute Updated Agreement”  -- provides for the 
> possibility that ICANN will enter into a revised “form Registrar 
> accreditation agreement” into which a registrar could “elect” to enter.  The 
> procedure for updating the RAA appears to be on a different track from the 
> amendment process and the BC requests more information on this process and 
> wishes to understand the repercussions of having some registrars elect to 
> enter into a new agreement while others might elect to stay with the current 
> accreditation agreement.  
>  
> Please do your final review by 30-May-2013 so that we can submit to ICANN.   
> Any objections or edits should be sent as Reply to All. 
> 
> Thanks again to Anjali Hansen, Elisa Cooper, Susan Kawaguchi, and others for 
> work on this draft.
> 
> --Steve
> 
> From: Steve DelBianco <sdelbianco@xxxxxxxxxxxxx>
> Date: Tuesday, May 14, 2013 7:45 AM
> To: "bc-gnso@xxxxxxxxx" <bc-gnso@xxxxxxxxx>
> Cc: "Hansen, Anjali" <AHansen@xxxxxxxxxxxxxxx>
> Subject: FOR REVIEW: draft BC comment on proposed final 2013 RAA (Registrar 
> Accreditation Agreement)
> 
> ICANN has posted the proposed final 2013 RAA (Registrar Accreditation 
> Agreement) for public comment. (link) 
> 
> Anjali Hansen admirably volunteered to draft BC comments.  Several BC members 
> provided input, including Ron Andruff, Bill Smith, Susan Kawaguchi, Zahid 
> Jamil, and Elisa Cooper.  
> 
> We held a conference call on this topic on 2-May where many others provided 
> ideas. (call minutes and Transcript )
> 
> Still, Anjali shows several pending questions in the attached draft.   We 
> need further help from BC members with direct experience dealing with 
> registrars and privacy/proxy providers.
> 
> Comment period closes 4-Jun.   That allows our regular 14-day review and 
> approval period.  So, please REPLY ALL with your suggested edits and comments 
> regarding this draft, before 28-May-2013.
> 
> Steve DelBianco
> Vice chair for policy coordination
> Business Constituency
> 
>  
> From: owner-bc-gnso@xxxxxxxxx [mailto:owner-bc-gnso@xxxxxxxxx] On Behalf Of 
> Steve DelBianco
> Sent: Monday, April 08, 2013 2:54 AM
> To: 'bc - GNSO list'
> Subject: [bc-gnso] Notes from Monday 8-April Beijing session on new RAA
>  
> ICANN staff just spent an hour answering BC questions about the new RAA 
> (registrar Accreditation Agreement).
>  
> The main element of controversy is the process for ICANN to amend the RAA. On 
> 2-April, ICANN proposed a new amendment process (link)
>  
> The notes below may be helpful for volunteers Anjali Hansen and Zahid Jamil, 
> who volunteered last week to draft BC  comments on the new RAA.
>  
> Law enforcement items were first priority for negotiation.  ICANN says the 
> LEA items are agreed by registrars, so ICANN added a dozen “new asks”, incl: 
> - EBERO, Registrant Rights, data escrow, abuse contact, 
> - obligations for registrars using Resellers, 
> - greater compliance tools, incl provision that “pattern or practice of 
> cybersquatting” is grounds for termination )
>  
> Made progress on privacy /proxy services (P/P) since Toronto.   Temporary P/P 
> specification while ICANN develops accreditation program.   In response to a 
> compliance question, Samantha said the P/P Spec sets high level principles 
> that are actually easy to enforce.   At my request, Susan Kawaguchi is 
> drafting BC comment on just this specification since she has significant 
> experience with P/P issues.
>  
> I asked about delay to the P/P accreditation in light of the Expert Group on 
> Directory Services.   Samantha said that Registrars truly want ICANN to do a 
> P/P accreditation program so it would apply to all P/P providers – not just 
> those affiliated with Registrars who have to sign the RAA.
>  
> RAA will be a model document, so its not subject to negotiation with each 
> registrar (except for bilateral amendments).  So negotiations won’t be a 
> bottleneck for getting registrars on-board.
>  
> I asked whether the RAA needed exceptions for registrars created just to 
> service a dot-brand gTLD.  (single registrant, single-user) Such as 
> transition on termination; Rights to data; transfers, etc.    Staff and BC 
> members could not come up with concerns that would call for exceptions.
>  
> Public comment would be valuable in these areas:  
> Registrant rights & responsibilities.  This was drafted by registrars.
> Validation of registrant data (registrant and account holder?)
> Penalties for inaccurate data
> Registrars want to drop Port 43 access for thick registries
> Unilateral amendment by ICANN.  See Cyrus blog on 2-Apr
>  
> Ron Andruff asked if the next iteration of the RAA will be posted for public 
> comment.  Answer was not definitive, so I asked Ron to draft a couple 
> paragraphs of rationale for BC comments. 
>  
> <BC Comment on final RAA draft 5-28-2013.docx>