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Comment from Byron Holland on Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Strings

  • To: "comments-pab-new-gtld-strings-21mar14@xxxxxxxxx" <comments-pab-new-gtld-strings-21mar14@xxxxxxxxx>
  • Subject: Comment from Byron Holland on Mandatory Policy Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Strings
  • From: Mark Buell <mark.buell@xxxxxxx>
  • Date: Tue, 15 Apr 2014 15:13:10 +0000

Attached is a commentary of the proposal for the Use of Mandatory Policy 
Advisory Boards for Regulated Industry Sector and Consumer-Trust-Sensitive New 
gTLD Strings.


Byron Holland

Comment on the Proposal for the Use of Mandatory Policy Advisory Boards for 
Regulated Industry Sector and Consumer-Trust-Sensitive New gTLD Strings

April 11, 2014


While I in general believe the idea of Policy Advisory Boards to implement 
safeguard advice for "sensitive string" gTLDs associated with regulated 
industries and professions to address the concerns expressed by the 
Governmental Advisory Committee (GAC) to be conceptually sound. In particular, 
we support the proposal of an entity made that includes broad representation to 
ensure consumer trust in the Internet.
However, the following concerns regarding the practical implementation of such 
boards have been identified:

*         Funding: In my opinion, any processes to safeguard the public 
interest with regard to the delegation of sensitive strings must balance the 
need of ensuring consumer trust and confidence in the Internet with the need to 
minimize the impact of the liabilities on new registries. Requiring gTLD 
applicants to fund the activities of the PAB constitutes a change in the 
application process since the call for new gTLDs was released in 2012. 
Registries should not be burdened by excessive administration costs.

*         Membership: The proposed membership includes representation from at 
least three groups that could be considered special interest groups: advocates, 
consumers and benefitting organizations, and constituent groups.  While broad 
participation on the Board will be critical to its credibility and success, an 
over-representation of organizations that come to the table with an agenda or 
entrenched positions will be detrimental to the decision-making process.

*         Decision-making processes: Consensus decision-making is a hallmark of 
the multi-stakeholder process, and must be utilized in decisions about 
sensitive string gTLDs. However, it is also a challenging process when there is 
a diversity of opinions involved. With the proposed membership that includes 
numerous advocacy groups, I believe that consensus will be difficult to 
achieve. To ensure decisions are made in the best interest of the public, they 
must be based in evidence. For this reason, decisions must be based in 
impartial and unbiased research into the impact of sensitive string gTLDs on 
regulated industries and professions, as well as the public interest.

*         Definitions of regulated industries and professions: The same legal 
frameworks that apply for the use of sensitive strings involving regulated 
industries in the 'offline world' must also apply in the 'online world'. 
However, protocols for verifying and licencing regulated industries vary widely 
among nations and global regions. The identification of expert members with the 
ability to accurately and effectively represent a regulated industry or 
profession, such as .DOCTOR, will prove difficult. Furthermore, registries 
should have a degree of flexibility in how they implement the safeguards, 
recognizing national legal frameworks.

Attachment: Comment by Byron Holland on Policy Advisory Board proposal.docx
Description: Comment by Byron Holland on Policy Advisory Board proposal.docx



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