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

[Sherry S]

Dear Farzaneh,

Unfortunately, I will not be able to attend the policy call today. However, I want to express support to the position as outlined in the draft, particularly the concerns regarding prioritising Associated Domain Check given the significant privacy, surveillance, and unfair takedown risks it poses to registrants.

Best regards,
Sherry

> On 8 Dec 2025, at 6:34 AM, farzaneh badii <farzaneh.badii at gmail.com> wrote:
> 
> 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 

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://lists.ncsg.is/pipermail/ncsg-discuss/attachments/20251208/4d0f1c0c/attachment-0001.htm>