[ALAC] Preliminary Issue Report on the Inter-Registrar Transfer Policy (IRTP) Part D

[Alan Greenberg]

I was asked for an opinion on whether an ALAC statement is necessary 
on the 
<https://community.icann.org/display/alacpolicydev/At-Large+Preliminary+Issue+Report+on+the+Inter-Registrar+Transfer+Policy+%28IRTP%29+Part+D+Workspace>Preliminary 
Issue Report on the Inter-Registrar Transfer Policy (IRTP) Part D.

The short answer is that I do not believe that a statement is 
required, but I would appreciate a "sense of the ALAC" that this PDP 
should be initiated.

IRTP-D is the last of a set of PDP's to review and possibly update 
various aspects of the Inter-Registrar transfer Policy (IRTP). IRTP-D 
consideres:

a) Whether reporting requirements for registries and dispute 
providers should be developed, in order to make precedent and trend 
information available to the community and allow reference to past 
cases in dispute submissions;

b) Whether additional provisions should be included in the TDRP 
(Transfer Dispute Resolution Policy) on how to handle disputes when 
multiple transfers have occurred;

c) Whether dispute options for registrants should be developed and 
implemented as part of the policy (registrants currently depend on 
registrars to initiate a dispute on their behalf);

d) Whether requirements or best practices should be put into place 
for registrars to make information on transfer dispute resolution 
options available to registrants;

e) Whether existing penalties for policy violations are sufficient or 
if additional provisions/penalties for specific violations should be 
added into the policy;

f) Whether the universal adoption and implementation of EPP AuthInfo 
codes has eliminated the need of FOAs (Forms of Authorization).

This Public Comment is an opportunity to identify errors or omissions 
in the Preliminary Issue Report, and to provide support for 
initiating the PDP. O know of no specific errors or omissions. 
Although I support the PDP going forward, given the long history 
which got us to this stage, I am not expecting much opposition so I 
do not feel that a written comment is worth the effort.

The PDP does address a number of issues that could benefit 
registrants and for that reason I do believe that it should go ahead. 
If the ALAC agrees, I would like to carry that message forward. I 
would also strongly advise that there be At-Large representatives on 
the resultant WG.

Alan