Comment on Bylaw 4.6 - Reviews

[Holly Raiche <h.raiche@xxxxxxxxxxxxxxxx>]

This comment is more about the implementation of a specific Bylaw than the 
actual Bylaw.

Bylaw 4.6 (e) Specific Reviews - Registration Directory Service Review requires 
(under (iv) and (v) that an RDS Review (iv) assess the extent to which prior 
RDS review recommendations have been implemented and (v) that an RDS review be 
conducted at least every five years from the date of the last review.

The last RDS Review - The Whois Review Final Report - was released in May 2012. 
 Arguably, that would mean that the next RDS review be held within the next 
year.  However, a GNSO WG on the many issues surrounding RDS has been 
established within the past year, and given its broad charter, is not likely to 
complete its charter tasks within the next year - or two (let alone have Board 
acceptance of the Review and its implementation.  

While there is limited scope for a review of the implementation of 
recommendations from the last Whois Review, there is no point to establishing a 
broader RDS review while ever the current RDS WG is working through its Charter 
tasks.  

Therefore, compliance with the By-laws on an RDS review - if it is conducted at 
all - should be a very limited one, recognising that those in the community 
(members of GNSO, ALAC and other communities) that are concerned about RDS 
issues are already committed to addressing RDS issues as part of the current 
GNSO RDS WG - with little if any time or resources to participate in another 
RDS review.

The consequence for the wording of these provisions of the Bylaw on RDS reviews 
should, therefore, be worded so as to maintain a commitment to the ongoing 
review of RDS - but not take effect until the current RDS WG Charter tasks are 
complete and the Board has accepted the final report

Holly Raiche
ALAC