We thank the NCAP Discussion Group for their work on the Draft NCAP Study 2 and its associated report, and we appreciate this opportunity to comment on that work.  

We understand that the core recommendation is for a new Name Collision Risk Assessment Framework to replace the Name Collision Management Framework used in the last TLD application round and we appreciate the detailed work on this. We are concerned, however, at the lack of any estimated time frame linked to the Name Collision Risk Assessment Framework workflow. A previous iteration of the workflow, presented last Autumn, did include estimated timings for the different stages of the workflow, as did the Controlled Interruption process used during the last round of new gTLDs. While we understand it may not be possible to be absolute in predicting a time frame for conducting the risk assessment for a TLD, it is important that applicants have some idea of how long a “typical” risk assessment is likely to take, with the understanding that if issues are discovered then the assessment may take longer. Therefore, we would urge you to consider attaching estimated time frames to the risk assessment workflow to provide a level of predictability for applicants.  

In addition, we suggest the risk assessment process should begin as soon as possible following the publication of the applied-for TLDs in the next round, running in parallel with the application evaluation and prior to other associated processes (e.g. objections, contention resolution, etc.). This will help the efficiency of the overall process, helping to avoid applications being rejected on the basis of name collision issues after the applicant has already spent considerable time and resources on navigating other obstacles, such as objections. Further, whether there is a name collision risk requiring mitigation is likely to be a factor applicants would take into consideration when seeking to resolve contention. 

Thank you for your consideration of these comments. 

We urge the Discussion Group to attach estimated time frames to the name collision risk assessment workflow outlined in the report to provide some predictability for applicants. We also ask you to consider advising that the risk assessment analysis commence as soon as possible after the publication of the applied-for TLDs, and certainly prior to other TLD assessment procedures such as objections and contention resolution.