Comment ccNSOAG3:

[Marianne Wolfsgruber <gm@xxxxxxxxx>]

Please find attached the agreed position from CENTR.


Marianne Wolfsgruber
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General Manager
Council of European National TLD Registries
Dreifaltigkeitsgasse 3/100, 5020 Salzburg, Austria
  www.centr.org  Ph(at) +43 662 872563 11, Ph(uk) +44 1865 332400

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At its General Assembly Meeting on November 21st and 22nd in Leuven CENTR 
reviewed and discussed the ccSO's Assistance Group's Preliminary 
Recommendation on Policy-Development Process. While CENTR welcomes the 
Assistance Group's efforts to make some considerable progress in the 
creation of the framework for the future ccSO CENTR is deeply concerned 
about the considerable lack of time which forces undue haste on the 
Assistance Group itself as well as on the ccTLD community as a whole. It 
might be due to this undue haste that the Preliminary Recommendation is not 
satisfactory in its current form.

Albeit CENTR understands that the Recommendation does not deal with the 
scope of the ccSO it needs to be emphasized again that neither the ccSO nor 
the ICANN Board must be able to set binding policies for ccTLDs in a 
general sense. Instead, the policy dealt with by ccSO and ICANN Board shall 
only concern the core IANA function. Regardless of this limitation, CENTR 
is in favour of the ccTLD community developing best practices guidelines 
and envisages the ccSO to be a suitable forum for this, along with e. g. 
the regional organizations that have already proven to be capable of 
fulfilling such a task. Also, CENTR considers the ccSO as a convenient tool 
to foster the dialogue between ccTLDs and the other parts of the ICANN 
community.

Moreover, CENTR is of the opinion that the development of policies with 
regard to the IANA function and the implementation of such policies need to 
be separated organizationally.

Besides these more general remarks, CENTR regards the Recommendation's 
notion of an Issue Manager responsible to manage the whole 
policy-development process as unacceptable. If the ccSO's Council finds it 
necessary to get some administrative assistance in the course of a 
policy-development process, it has to be up to the Council itself to choose 
one or, if need be, several persons for that and it would seem wise if 
these persons then came from the ccTLD community or the ccTLD secretariat.

Furthermore, CENTR is not satisfied with the majorities as laid out in the 
Recommendation for starting a policy-development process, agreeing on a 
policy within the ccSO's Council and having it adopted by the ICANN Board. 
With regard to all decisions of the Council it has to be ensured that no 
more than one of the five ICANN regions can be outvoted there. Also, the 
majority of 50 per cent as defined in the Recommendation appears to be 
insufficient. Regarding the ICANN Board it has to be clear that it must not 
be able to adopt a policy affecting the ccTLD community that has not been 
recommended by the ccSO, let alone a policy that has not even gone through 
the ccSO's policy-development process.

Finally, CENTR is concerned about the Recommendation's rather narrow 
timelines for the policy-development process. Particularly in light of the 
ccTLD community's diversity there will usually more time be needed for 
thorough consideration and deliberation.

CENTR members may revisit any or all of the matters discussed above in the 
context of the full set of finalized proposals including all matters not 
dealt with to date.