[Ncsg-discuss] [important] Policy committee meeting in a few hours: DNS Abuse PDPs

[farzaneh badii]

Dear all,

Our policy committee meeting which will happen tomorrow is very important
and if you care about the following issues, please attend:

1. The council leadership has suggested a motion on DNS abuse PDP. We had a
conversation here on the mailing list and pointed out the problems that we
identified with the motion.
Find the motion here:
https://icann-community.atlassian.net/wiki/spaces/gnsocouncilmeetings/pages/111126628/Motions+2025-12-11

2. The issues we have identified:
- this motion was sent to the council to be considered right on the day the
staff provided the final issue report. We had no time to read the issue
report.
- the issue report mentions that there should be two PDPs, one about
Associated Domain Check and one about Safeguards for access to API. The
report mentions that they should be concurrent but the motion mentions that
there will be one PDP first (associated domain check) and then another PDP
(API). We supported a phased approach to tackle one issue and then go to
the next one. But here the motion wants to do two PDPs, not concurrent ones
and it has already chosen the associated domain check as the first PDP. We
just don't know how that happened and how it was decided. We withdrew our
support from focusing on associated domain check because of the significant
risk it could have to access and unfair take-down and lead to profiling and
surveillance. We don't know how it was decided to do associated domain
check first.
- We need drafting teams to modify the charters. The charter questions have
disregarded our questions and concerns.


Peter has written this position for us to discuss with you and then send to
the GNSO Council list. I have made some changes to it. But it reads:

*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. Moreover, it seems that the final
issue report still recommends concurrent PDPs despite our emphasis that
they should not be concurrent which makes the process more ambiguous.

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. We also believe the PDP participants should
decide which topics they should prioritize and provide a rationale for it,
with clear timelines.

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 and for API
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.
However  caution against 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 and how to move forward on convening the PDPs and
drafting the charters and focusing on issues.


Best regards,






























[1] Please see what staff recommended in the issue report: Based on the
community Input, the Staff Manager has included two draft Charters on the
two
priority topics for GNSO Council consideration. Breaking the work into a
set of targeted and concurrent PDPs (for example: PDP 1 on two priority
issues, PDP 2 on subsequent priority gaps, etc.) could make each effort
more focused and faster on its topic. The downside is managing multiple
simultaneous PDP WGs, which can strain community volunteer and staff
resources. Coordination would also be needed to ensure no gaps or overlaps
between them. Given community feedback to date, there appears to be
interest in a narrowly scoped approach. To that end, staff recommends
initiating two PDPs, focusing on the two priority issues, with the option
to initiate additional PDPs subsequently. This approach balances urgency
with
manageability."
https://gnso.icann.org/sites/default/files/policy/2025/draft/issue-report-dns-abuse-mitigation-01dec25-en.pdf
page
39
Farzaneh
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