This attachment contains the full formal submission from the Non-Commercial Stakeholder Group (NCSG) regarding the "Additional Reference Label Generation Rules and Related Updates" public comment proceeding. It details our core recommendations regarding the intersection of Reference LGR development, Universal Acceptance, and the need for enhanced transparency, accountability, and community-led monitoring of real-world impact. This attachment provides the complete, contextualized feedback that supports the high-level summary provided in the online form.

The Non-Commercial Stakeholder Group (NCSG) supports the publication of the proposed new and updated Second-Level Reference Label Generation Rules (LGRs). Our position emphasizes that technical availability is not sufficient; ICANN must prioritize "meaningful access" to ensure domain names can be discovered, registered, and used across the internet ecosystem. We explicitly welcome the inclusion of support for UCAS, Algonquian, Javanese, and Pegon scripts as a positive step toward global inclusivity. However, we urge ICANN to increase transparency regarding the LGR development process, specifically by providing clearer rationales for character additions and accessible pathways for community participation. Furthermore, we recommend the establishment of formal mechanisms to monitor the real-world impact and adoption of these LGRs among registries and end users to ensure they effectively bridge the digital divide for historically underrepresented linguistic communities. This submission serves as the formal expression of our views on this proceeding.