Hi Stepahnie & Farzi,

thanks for the great work in such a short time. I support your approach.

I do have only small comments. 

My key issue is looking forward, that means to make sure that the next
steps (tiered&layered system) are in full compliance with the new ICANN
bylaws and its human rights based commitments. 

The issue, that "full transparency" means "full participation in PDP",
is such a key issue and should get first prirotiy. A strong argument
(since years) is that the GAC sofar has overreprsented LEAs and
underrepresented DPAs. Even the EU was silent when 5 years ago Suzanne
pushed for LEA Rec.11 in the GAC and she got it without any objection
from the EU for the RAAs. Article 29 WG was watered down and nobody
objected in the GAC. If the Board gets GAC Consensus advice (as it was
with the LEA Recs./RAA) it is difficult to change it. Fadi (and many
board members) did not like it. But to get the RAA done was an important
step towards the IANA transition. Now we have a different time, althoug
under the new bylaws it is now even more complicated for the board to
reject GAC Consensus advice. 

So you have to work with the EU GAC rep to make sure, that the EU itself
fights for its philosophy and legislation within the GAC. Transparency
within the GAC would be a step forward. Building NCUC partnership with
like minded GAC members is an important element. Bottom up
multistakeholder PDP includes state/non-state actors collaboration from
the very first moment. This is BTW "pure enhanced cooperation" under
para. 69 - 71 of the Tunis Agenda. Just do it!!!

The Board plays certainly a central role, but in this case the board is
also sandwiched between the GAC and and a splintered community. To
attack the board (from a NCUC perspective) could have an unintended
sideeffect to weaken the board in its battle with "radical GAC members"
to go forward towards "balanced" solutions. To have a strong GDRP
Rainbow coalition with like minded GOVs and like minded non-state
stakeholderrs (what about IETF?) is key (ignore or reject Tony Rutkowski
who delievers dangerous poison). 

Small steps are not bad. It doesn´t help too much to repeat too often
that we have said this since 20 years. Yes, it is correct. In remember
Santiago de Chile in September 1999. Since that: "The same procedure
like every year.:-)))"

But everybody knows this. The battle is here, now and in the years
ahaed. To work with Catanacci is also a good option. And what about LEAs
in China and Russia?

Best wishes and hope to see you in Panama. 
   






>>> Stephanie Perrin <[log in to unmask]> 10.03.18 23.20
Uhr >>>
     As many will know,           ICANN released a lengthy report on its
proposed model for           compliance with the GDPR on March 8.  
         
    
https://www.icann.org/resources/pages/data-protection-announcements-2017-12-08-en
           
         
     Because of the urgency           of ongoing discussions at the
ICANN 61 meeting in San Juan, we           have responded with our
preliminary comments.  Attached is a           draft letter, your
feedback is most welcome, but we need to           get the letter out in
24 hours as the meeting starts Monday           with a GDPR cross
community session at 10 am.  
         
     Thanks very much.
     Stephanie Perrin