The IPC strongly supports additional improvements to the mitigation policies and contract requirements related to DNS Abuse, whether through the initiation of a GNSO Policy Development Process (PDP) focused on DNS abuse or through additional bi-lateral contract negotiations, whichever is quicker. The IPC believes that additional gaps highlighted in the PIR should be addressed concurrently or in parallel, rather than postponed for years. Rather than endure years of policy making, ICANN should consider contract negotiations as an alternative approach to a PDP. Traditional PDP timelines are lengthy, yet the abuse problem is dynamic and accelerating. The community cannot afford to tackle these issues sequentially over a half-decade. Instead, we echo the Business Constituency’s call for a more nimble, iterative policy process that can adapt and expand as new DNS abuse vectors emerge.

In short, if alternative approaches to a PDP are not feasible, the IPC urges the GNSO to treat the PIR’s gap list holistically – launch the first PDP on the two core items, but simultaneously lay the groundwork (charters, drafting teams, staff support) to address the other critical gaps through additional policy work or other means. We note and support the PIR’s suggestion that some issues might be handled outside formal policy if faster results are achievable. For instance, ICANN Contractual Compliance could tighten enforcement of existing obligations (by terminating bad acting registrars that fail to meet their DNS abuse obligations) or negotiate additional RAA amendments, and the community could form a cross-functional task force to handle certain operational fixes and suggest negotiation topics. The IPC is open to innovative approaches – what matters is results.