Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
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I am writing to express deep concern regarding the recent modifications to the Community Priority Evaluation (CPE) criteria proposed in the final draft of the Applicant Guidebook (AGB), particularly those found in Module 4, Section 4.4. As Chair of the Not-for-Profit Operational Concerns Constituency (NPOC) and a member of the Subsequent Procedures Implementation Review Team (IRT), I have been committed to ensuring that the voices of noncommercial organizations and community-based groups are properly reflected and protected within ICANN’s policy development and implementation processes. The recent changes to the CPE rules, however, deviate significantly from this goal. The modifications—particularly the restrictions placed on CPE panelists’ ability to use independent research, the narrowed definitions of “majority” and “nexus,” and the prioritization of the applicant’s self-perception over external perspectives—undermine the very purpose of Community Priority Evaluation. These changes risk silencing legitimate communities, including Indigenous Peoples, civil society organizations, and long-standing NGOs that have built their identities around specific names and causes. CPE was intended as a mechanism to safeguard authentic community interests in cases of contention. By weakening the evaluative tools and neutralizing external input, the revised criteria create an environment ripe for the misappropriation of names by unrelated or marginally connected entities—at the expense of legitimate, often vulnerable, community stakeholders. I urge the ICANN Board and the IRT leadership to reconsider these recent alterations and restore the original policy language that better balanced fairness, accountability, and community protection. We must not allow the technicalities of implementation to override the inclusive spirit and intent of the original policy recommendations.