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

[Bruna Martins dos Santos]

Hey all,

Just informing the list that after our Policy Meeting we have sent the
email below to the Council list:

______

Dear Council,

In light of this week's meeting and motion regarding the DNS Abuse PDP, I
would like to share the following position from the NCSG:

*NCSG Position on the DNS Abuse PDPs*

*The Noncommercial Stakeholders Group (NCSG) acknowledges the importance of
ICANN’s DNS Abuse mitigation efforts? and recognizes the Council's
extensive discussions, public comments, and ongoing efforts in this area.
However, the NCSG has significant concerns regarding the motions submitted
to the Council list.The 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. Given the NCSG’s limited capacity
to engage, having two PDPs at the same time is not feasible. Having one PDP
completed in phases  would 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. The 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. This incongruity risks
causing confusion and requires Council discussion to resolve
them.Additionally, NCSG believes the Council should first discuss which
specific topics warrant prioritization based on the recommendations in the
Final Issue Report, and then provide recommendations of approaches to the
PDP regarding timelines and scope. We also believe the PDP participants
should decide which topics they should prioritize and provide a rationale
for it, with clear timelines.NCSG's most significant concern remains the
process itself. 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. 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. And
although it's not the first time a draft charter emerges from a final
issues report, the GNSO council holds the role of managing PDPs and,
therefore, the role of scoping said efforts. Adequate deliberation on these
structural questions is essential to ensuring that the Working Group can
function effectively and that NCSG can participate meaningfully, as well as
a drafting team for finalizing the charter/charters. To conclude, the NCSG
does not oppose convening PDPs on the identified topics. However, we
caution against prioritizing the Associated Domain Check initiative, as it
raises significant concerns regarding registrant privacy and identification
risks.The 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. ****In a nutshell, the NCSG
will defer a vote on this motion, and we would welcome if more time was
allocated during our upcoming meeting to address these issues and the final
issues report.

We remain at your disposal in case any doubts arise!

Kind regards,


On Fri, Dec 5, 2025 at 11:32 PM Akinremi Peter Taiwo <compsoftnet at gmail.com>
wrote:

> 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>
> ___________________________________________
>


-- 

*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
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