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.
Attached PDF file contains our comments.
We thank the IRT for its current work, but note that there is more to do.
Implementation must not go beyond the limits set by the Working Group, much less innovate
in relation to what was previously decided, and Implementation Guidance, when provided
with great care and detail, should be followed. To these ends, NCSG recommends a number of amendments and clarifications, outlined in the full comments text.