The draft CPE Evaluation Guide is a significant and welcome step toward improving transparency, consistency, and predictability in Community Priority Evaluations. The effort to provide structured guidance to evaluators, including defined roles, evaluation workflows, and scoring rubrics, is commendable and reflects learnings from the 2012 round.

However, given the high-stakes nature of CPE as a contention resolution mechanism, it is essential that the guide minimizes subjectivity, strengthens consistency across evaluation panels, and ensures equitable treatment of diverse global communities. In its current form, several areas would benefit from further clarification and enhancement.

Need for Greater Objectivity and Measurable Benchmarks : While the guide outlines detailed qualitative considerations, many evaluation elements rely on subjective interpretation (e.g., “recognized community,” “majority support,” “general public association,” and “relevant opposition”). This introduces a risk of inconsistent outcomes across evaluators and panels. Thus it is recommended that ICANN Introduce clearer measurable indicators or scoring anchors where feasible, Provide illustrative examples or case scenarios across different community types and Develop standardized evaluation templates to ensure uniform documentation of rationale.

Standardization of “Independent Research” : The guide allows evaluators to conduct limited independent research, including consulting experts. While this is useful, the absence of a defined methodology raises concerns regarding reproducibility, transparency, and potential bias. Thus it is recommended that A standard protocol for independent research be defined, All external sources and expert consultations be fully documented and auditable and Applicants be given visibility or opportunity to respond to externally sourced inputs impacting scoring.

Clarification on “Majority Support” and “Relevant Opposition”: Criterion 4 (Community Endorsement) is one of the most critical and potentially contentious areas. The current guidance lacks clarity on: How “majority” is calculated (by number of organizations, individuals, geographic spread, or influence), How to weigh quality vs. quantity of support/opposition and How to assess fragmented or decentralized communities. It is recommended to Define clear methodologies or acceptable approaches for determining majority, Provide weighting guidance for different types of supporting/opposing entities and Include safeguards against strategic or obstructive opposition.

Inclusivity of Diverse Community Structures (Global South Perspective) : The current framework appears to implicitly favor formal, structured, and institution-driven communities. This may unintentionally disadvantage Informal or grassroots communities, Digitally native or decentralized communities and Communities in developing regions with limited formal documentation. Thus It is recommended that the guide Explicitly recognize alternative forms of community organization and engagement, Provide flexibility in acceptable evidence types, including digital engagement and participation metrics and Ensure evaluators are trained to assess non-traditional community structures fairly

Consideration for Linguistic Communities, IDNs, and Universal Acceptance: While the guide briefly references IDNs, there is insufficient depth in addressing how linguistic and script-based communities should be evaluated, particularly where The applied-for string is in a local language or script

Community awareness and engagement occur in non-English environments, Evidence may not be readily discoverable through conventional (English-centric) research methods. Thus It is recommended that Additional guidance be provided for evaluating IDN-based applications and linguistic communities, Evaluators be encouraged to consider local language evidence and context and Alignment with Universal Acceptance (UA) principles be strengthened to ensure equitable evaluation across scripts and languages

Strengthening Consistency Through Calibration and Quality Assurance: The inclusion of calibration sessions and QA processes is a positive step. However, given the inherent subjectivity in several criteria, stronger safeguards may be needed. Recommendations include Publishing anonymized sample evaluations as reference benchmarks, Introducing cross-panel consistency checks and Ensuring continuous feedback loops between ICANN, QA providers, and evaluators

Transparency and Applicant Confidence: Given the impact of CPE outcomes, it is critical that applicants have confidence in the fairness and rigor of the process. It is recommended that Evaluation reports provide clear, structured, and evidence-backed reasoning, Greater transparency be ensured in how external inputs influence scoring and The process remains predictable and defensible under scrutiny

In the end I again acknowledge that the draft guide is a strong foundational document and reflects ICANN’s commitment to improving the CPE process. With targeted refinements particularly around objectivity, consistency, inclusivity, and global applicability it can evolve into a robust and trusted framework that serves the diverse global Internet community effectively.

I welcomes the development of the draft CPE Evaluation Guide as an important step toward improving transparency and consistency in Community Priority Evaluations for the New gTLD Program: 2026 Round. However, given the critical role of CPE in contention resolution, the guide would benefit from further strengthening in several areas. Key recommendations include enhancing objectivity by introducing clearer measurable benchmarks and illustrative examples, standardizing the methodology for independent research to ensure transparency and auditability, and providing clearer guidance on determining “majority support” and evaluating “relevant opposition.” The submission also highlights the need to ensure inclusivity of diverse global community structures, particularly informal, grassroots, and digitally native communities, which may not always have formal documentation. Additional guidance is recommended for evaluating linguistic communities and Internationalized Domain Names (IDNs), ensuring alignment with Universal Acceptance (UA) principles and equitable treatment across languages and scripts. Further, strengthening calibration, quality assurance mechanisms, and transparency in evaluation reporting will improve consistency and applicant confidence in the process. Overall, with targeted refinements, the evaluation guide can become a robust, fair, and globally inclusive framework that supports the diverse nature of the Internet community.