Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Registries.

[Christopher Wilkinson <cw@xxxxxxxxxxxxxxxxxxxxxxx>]

Mandatory Policy Advisory Boards for Regulated Industry Sector and 
Consumer-Trust-Sensitive New gTLD Registries.
I do not support this proposal. If these new gTLD are subject to such risks of 
egregious malpractice that even the industries that they are supposed to serve 
do not support them, let alone their regulatory agencies and governments, then 
these 'strings' should not be delegated at all.
The proposed Policy Advisory Boards are clearly a palliative for a wider issue 
that has not yet been addressed:
By constituting such ICANN-esque global regulatory agencies in each of the 
sectors concerned, ICANN would expose itself to unprecedented obligations and 
liabilities which it is in no position to discharge, world-wide.

There is no reference to the real costs of the Policy Advisory Boards, their 
autonomy, authority and their recourse in the event of disputes. 

To be meaningful in any sense, these PABs would require full-time professional 
positions. The original proposal refers to the PABs being financed exclusively 
by the Registry concerned, which is manifestly absurd. 
 They would have to be financed directly by ICANN, to ensure a minimum of 
independence.
The original proposal envisages a small PAB (12-18 members) for each Registry, 
representing eleven or more categories of interest groups, world-wide, not 
including governments. 
The internal inconsistency of the proposal is self-evident.

The proposed text sets the bar for compliance excessively low. Here we have the 
PAB ensuring that the Registry does not operate in a manner that is “... 
antithetical to the overriding goals of competition and innovation.” Nothing 
more?
Consequently, it would appear to be inconsistent with the public interest to 
pursue “the further development of the PAB model” until the eventual Registries 
themselves propose credible and viable global solutions to the issues that have 
been identified.

Regards

Christopher Wilkinson