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Name: Paul McGrady
Date: 21 Jul 2025
Email: [email protected]
Original Public Comment: Final Proceeding for Proposed Language for the Draft Next Round Applicant Guidebook (AGB)
4) Is the language in draft Module 4: Contention Set Resolution consistent with Board-approved recommendations, and are the concepts introduced therein consistent across the AGB? Please note that comments should be made on issues that have not been previously addressed via Public Comment or in discussions with the IRT.
No

If no, please explain

CPE lacks basic definitions and therefore is circular. It needs to define "Identified Community" and it needs another definition for the "Possible Community" otherwise all one need do is identify a small group of possible registrant and claim 100% nexus, etc. For example, if the town of Cherokee NC applies, they could claim a fulsome nexis to .cherokee but it fails to consider the nexus to the much larger Cherokee Nation. I have raised this issue publicly and privately. The problems that will occur due to a lack of definitional clarity are not hard to imagine, but so far the IRT seems to be resistant to doing these basic definitions. Please fix. Thanks!