[Ncsg-discuss] DNS Abuse PDP - Motion to be voted during next Council Meeting

[Akinremi Peter Taiwo]

Thank you, Bruna, for this email to gather NCSG position.

*I am responding inline with what I think. At the end, I started a draft
based on what it is that we want for editing.*

>
> Hope this email finds you well.
>
> I would like to resurface some of the discussions regarding the DNS Abuse
> PDP/PDPs.
>
> Back in Dublin, we had a lot of community engagement on this issue -
> championed by Farzaneh and Michaela - while the Council was first
> approaching the topic and waiting for the Final Issue Report.
>
> In many of our council debates about this, NCSG pointed out the following:
>
1.  Given the limited number of volunteers, we would prefer a phased
> approach instead of having two PDPs running at the same time.
>

*Response 1: I** believe this section of the motion directly addresses
NCSG's concerns regarding resource constraints and the timing of separate
PDPs. The motion explicitly recommends a phased approach, stating that "the
PDP on Associated Domain Check be started first, hereafter DNS Abuse
Mitigation PDP 1 and the PDP on Safeguards for unrestricted Application
Programming Interface (API) access, hereafter DNS Abuse Mitigation PDP 2,
second, when the Council decide it is an appropriate time taking into
consideration the progress and resources needed for DNS Abuse Mitigation
PDP 1."*

This language demonstrates that the Final Issue Report's recommendation
incorporates a resource-conscious, sequential approach. By explicitly
conditioning the start of DNS Abuse Mitigation PDP 2 on the Council's
assessment of progress and available resources from PDP 1, the motion
acknowledges the very constraints that NCSG raised. The sequencing
prioritizes the Associated Domain Check PDP first, which aligns with input
from public comments and Council discussion, while ensuring that the second
PDP will only commence when feasible.

Accordingly, we believe NCSG's concerns about resource constraints and the
risks of simultaneous PDPs have been adequately addressed through this
phased implementation structure.


2. In terms of the prioritization, we would prefer to start with the API
> discussion.
>

*Response 2: **The prioritization reflected in the Final Issue Report was
informed by community input through public comments and Council discussion.
We recognize that the API PDP should not go first, as it is a highly
technical area requiring specialized expertise that NCSG is not currently
positioned to lead effectively.*

*In contrast, the Associated Domain Check PDP aligns with NCSG's core
strengths and advocacy priorities. We have identified a champion who
understands our objectives, and this policy area is less technically
complex than the API discussion. More importantly, the central issues at
stake, identification versus contactability, are fundamental to NCSG's
mission and require our meaningful participation if this PDP is to succeed.
I would encourage NCSG to support the motion to begin with the Associated
Domain Check PDP, where our expertise and commitment can make the greatest
impact*



3. We would like for Council to further discuss the representation model,
> as well as decide on the approach before we start drafting the charter or
> charters.
>
> Recently the GNSO Council Leadership have forwarded a motion that draws
> on the Final Issue report and recommends two separate PDPs on (a)  Associated
> Domain Checks and (b) Safeguards for Application Programming Interface
> (API) access to new customers. Additionally, the motion suggests the
> Starting PDP should be Associated Domain Checks and already shares a
> draft charter.
>
> Although I understand that the draft motion Council will debate next week
> draws on the recommendations issued by the Final Issue report, I would
> like to highlight the following:
>
> 1. NCSG does not support two separate PDPs, and have mentioned
> during council meetings and community interactions that we would prefer a 2
> phased approach. And the main reason for that is the lack of people to join
> and follow both PDPs if they take place at the same time.
> 2. There was no such thing as a council vote on which would be the
> preferred topic to start with - because we never debated the charter nor
> the model appropriately.;
>

*Response 3: I** recognize the importance of reviewing the charter and
allowing sufficient time for deliberation, particularly regarding the
Working Group model and the Charter Questions/Scope. Based on feedback from
list discussions, NCSG has indicated support for both the representative
model and the open model approaches. We believe adequate time for this
charter review process is essential to ensuring that the Working Group
structure reflects NCSG's preferences and enables effective participation
in the PDP.*

>
> 3. This feels like a rushed decision, and I believe the council would need
> to reflect on what's best for us without having such a motion at the table.
>
*Response 4:* *While I share the concern that this process is being rushed,
I find it difficult to pinpoint the specific area where the pace is
problematic. Is the rush centered on voting on the Final Issue Report to
initiate the PDP, on the charter drafting itself, or on the entire process
from start to finish? Given the Council's ongoing efforts on DNS abuse
mitigation and the multiple conversations already underway regarding
address domain name abuse, we should take time to discuss and clarify where
exactly the timeline is compressed and what the appropriate next steps
should be. We need to identify which phase(s) of the process require
additional time and to determine what specific outcomes or deliberations
must occur before we can responsibly move forward*

>
> Writing this email just so we can gather some views on the issue and to
> help guide Peter's chats w/ the Leadership. And please, feel free to point
> out in case I'm misrepresenting any of our discussions.
>
> Looking forward to hearing from my fellow councilors and membership.
>
> Best,
>
>
*NCSG Position Draft: *

The Noncommercial Stakeholders Group (NCSG) acknowledges the importance of
the DNS Abuse topic and recognizes the Council's extensive discussions,
public comments, and ongoing efforts in this area. However, we have
significant concerns regarding the motions submitted to the Council list.

NCSG acknowledges the motion's sequential framing; the practical effect
remains two separate PDPs rather than a truly integrated phased
workstream. We therefore do not support establishing two separate PDPs as
proposed in the motion. It does not ensure NCSG capacity throughout the
overall process. While the motion indicates that PDP 1 will focus on
Associated Domain Checks and PDP 2 on API functionality, the language
stating that "the GNSO Council will revisit the draft Charter on DNS Abuse
Mitigation PDP 2 when deemed appropriate based upon the progress and
resources needed for PDP 1" does not clearly establish whether these
constitute phased workstreams or truly separate PDPs. NCSG would prefer a
phased PDP approach rather than two concurrent or sequential independent
processes for these related topics.

Additionally, NCSG believes the Council should first discuss and vote on
which specific topics warrant prioritization based on the recommendations
in the Final Issue Report. There has been insufficient deliberation
regarding the charter structure and the working group model to be adopted
during the PDP process. In our view, proceeding without this proper
discussion risks a rushed process that could result in inadequate review
and unsound policy outcomes.

NCSG's most significant concern remains the process itself. The motion
presents a draft charter for the Associated Domain Check PDP before the
Council has thoroughly discussed and decided upon the representation and
working group model to be adopted. Adequate deliberation on these
structural questions is essential to ensuring that the Working Group can
function effectively and that NCSG can participate meaningfully.

In addition, NCSG does not oppose convening PDPs on the identified
topics—Associated Domain Checks and API functionality, we, therefore, urge
caution in prioritizing the Associated Domain Check initiative, as it
raises significant concerns regarding registrant privacy and identification
risks.

NCSG would appreciate deferring a vote on this motion while ensuring the
council thoroughly deliberates on the working group model and
representation structure.

> --
>
> *Bruna Martins dos Santos *
>
> Policy and Advocacy Manager | WITNESS <https://www.witness.org/>
>
> German Chancellor Fellow 21' (Bundeskanzler-Stipendiatin) | Alexander von
> Humboldt Foundation <https://www.humboldt-foundation.de/>
>
> Member | Coalizão Direitos na Rede <https://direitosnarede.org.br/>
>
> Twitter: @boomartins <https://twitter.com/boomartins> // Skype:
> bruna.martinsantos
> Email: bruna.mrtns at gmail.com
>


-- 
Best regards

*Taiwo Peter Akinremi*
------ ------ -------  ------ ------ -------  ------ ------ ------- ------
------ -------  ------ ------
*Phd Candidate | Principal & Executive Consultant, CSN*
*Email:* compsoftnet at gmail.com, p-taiwo at compsoftnet.com.ng
<peterexecute at gmail.com>
___________________________________________
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://lists.ncsg.is/pipermail/ncsg-discuss/attachments/20251205/e7a535a7/attachment-0001.htm>