Comment ccNSOAG3:

[DPF <david@xxxxxxxxxx>]

Thanks for the useful document.  Upon first reading there are a few
things which clarification would help with.  

If the process is merely a policy of the Board is there any safeguard
against the Board changing it by simple majority at any time?  Can the
policy process itself be entrenched?  Perhaps made a condition of
contract?

I think most ccTLDs are of the view that any global policies developed
should be rare indeed and ones that have overwhelming consensus.  In
view of that, the thresholds of 33% of Council to initiate seem far
too low.  Also one should have a safeguard of minimum notice period of
a motion to initiate to ensure all regions are represented.

Every step relies pretty much on votes of the ccSO Council rather than
the entire ccSO.  As the global membership of ccSO is limited and well
defined I think there should be a step involving a vote by all ccTLDs.
Sole reliance on voting by regional reps on the Council can lead to
lack of a vote by some ccTLDs especially if they are in a permanent
minority in their region.

The term "Issue Manager" suddenly appears in the document without
defining what this is and who appoints them.  One can work some of
this out implicitly but a explicit reference would be useful.

The term "Supermajority" while defined elsewhere within ICANN should
also be defined in this document so it can be read and comprehended as
a stand alone document.

I am not convinced that two Regions alone should be able to force a
PDP initiation.  Again these should be very very rare.  I would prefer
a two thirds Council majority or 100% from three Regions.  And in the
case of a recommendation that this is out of scope, an 80% Council
vote needed or alternatively a two thirds vote of all member ccTLDs.
Main thrust is threshold too low.

20 days public participation is far too short for outreach to 200+
ccTLD local internet communities.  Again we don't want lots of ccTLD
policy being made quickly.  This should be a rarely used process.  I
would suggest 60 days as being more appropriate.  20 days won' even
allow individual ccTLDs to discuss issues at a regular monthly
meeting.

Likewise I would also allow 60 days for formulating regional
positions.

The Board by supermajority may vote to decline a recommendation from
the Council.  I note this has happened on numerous occasion with the
DNSO so may not be an unexpected event.  What is not clear if whether
the Board can substitute its own policy for the one it declines.  This
is very crucial to clarify.  

The acceptability of the proposed process will also depend on other
factors such as composition of ccSO Council and most importantly how
any policy will be implemented.  As 95% of ccTLDs do not have signed
contracts, presumably such policy will be voluntarily implemented.  Or
will ccSO membership rights be tied to signing a contract?  If so then
such contracts may want a guarantee of the policy process not being
able to be changed by the Board unilaterally.

DPF

(Note I am the Secretary of a ccTLD Manager, but the views expressed
are mine alone)