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Subject:
From:
Emmanuel Vitus <[log in to unmask]>
Reply To:
Emmanuel Vitus <[log in to unmask]>
Date:
Tue, 12 Mar 2024 10:53:40 +0100
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Thanks, @Manju, for the insights!

Just got back to France and dug into the ASP Handbook. Noticed a couple of
sticky points for non-commercial groups. @Tomslin Samme-Nlar
<[log in to unmask]>, please do we have any plans to sync up on our
comments? Maybe a quick call after the penholder @Bolutife Adisa
<[log in to unmask]> gathered our thoughts? The deadline's creeping
up, and we've got some important voices to represent :).

Below are suggested brainstorming ideas to enhance our submission:


   - *Financial and non-financial support clarity** (Section 2.1, Pages
   6-7): *While the handbook outlines various forms of support, the
   criteria for eligibility and the process for accessing certain supports
   (like bid credits or multipliers, and reduced Registry Operator fees) are
   pending Board consideration and research results.

*Possible c**ontentious point**:* This uncertainty could disadvantage
non-profit organizations which require clear information to plan their
applications.

*Comment:* Clearly define all forms of support, ensuring transparent
criteria are set early in the process to aid in planning and application
preparation.


   - *Eligibility criteria for non-profits and social impact organizations
   (Sections 5.5.1, 5.5.4, Pages 19-23):* The detailed criteria for
   eligible entities are comprehensive; however, the requirement for extensive
   documentation and the need to demonstrate a direct social impact or public
   benefit could be burdensome for smaller non-profits or newly established
   social enterprises.

*Possible c**ontentious point**:* The documentation and proof required
might be challenging for organizations with limited resources.

*Comment:* Introduce flexibility in the documentation requirements and
consider alternative evidence of impact and benefit that is easier for
smaller entities to provide (Especially those from the Global South).


   - *Language and Accessibility (General observation across the document):*
   The handbook is detailed and likely to be available primarily in English,
   which could pose a barrier to non-English speakers (*bearing in mind
   that 81% of the world's population does not speak English*).

*Possible c**ontentious point**:* The complexity of information and the
language barrier may discourage or disadvantage non-English speakers.

*Comment: * Provide the handbook and related resources in multiple UN
languages and consider translation support for application submissions.
Offering webinars or training in various languages could also help bridge
the gap. ( *Stephanie made a suggestion during the meeting in PR, we may
have to consider that in our submission*) .


   - *Clarifying questions and communication timelines (Section 7.3, Page
   32): *The process for clarifying questions allows for interaction
   between applicants and the Support Applicant Review Panels. However, the
   timeline for responses and the potential for additional questions could
   extend the evaluation period.

*Possible c**ontentious point: *Non-commercial stakeholders (applicants)
with limited resources may find it challenging to respond promptly,
especially if clarifications require additional documentation or
specialized input.

*Comment:*  Establish clear guidelines for the clarifying questions
process, including a fixed timeline for responses and a limitation on the
number of follow-up questions. Provide examples of common queries to help
applicants prepare in advance.


   - *General business due diligence and background screening (section 5.1,
   pages 12-13): *The necessity for legal compliance checks and background
   screenings is vital in upholding the credibility of applicants. Yet, the
   thoroughness of these procedures may unintentionally exclude organizations
   from areas where obtaining legal documents is challenging due to intricate
   regulatory systems.  (*Drawing on years of experience in the nonprofit**
   sector across Africa, I've observed that standard criteria set by
   international organizations often sideline businesses and organizations in
   the Global South when verifying documents. It's imperative for ICANN to
   collaborate with local agencies that can authenticate documentation while
   respecting the regional context and intricacies. For instance, Google
   employs TechSoup <https://www.techsoupafrica.org/en> in Africa to validate
   documents for non-profit beneficiaries. A similar approach by ICANN,
   embracing alternative verification methods, would be beneficial*).

*Possible c**ontentious point**:* Strict adherence to these criteria
without consideration for local contexts might exclude worthy applicants
from challenging environments.

*Comment:* Introduce a consideration clause for entities facing systemic
barriers in obtaining the required legal compliance documentation, allowing
for contextual evaluations through local/regional third parties.

My 2 cents.

Cheers,

Emmanuel

Le sam. 2 mars 2024 à 22:17, 陳曼茹 Manju Chen <[log in to unmask]> a écrit :

> Hi all,
>
> Below are the observations I shared during the Policy Meeting
>
> Generally I felt the process was indeed improved from the last round. Some
> improvements I noticed include:
>
>    - Applicant could still apply for the strings if they are not
>    qualified for Applicant Support.
>    - Applicant have to meet the criteria of 'Public Responsibility Due
>    Diligence'' (different from the Public Interest criteria from the last
>    round).
>    - Enhanced diversity in terms of eligibility requirements. (cause,
>    size of entity, indegeous groups, non-profit...)
>    - Updated financial stability criteria from the 'financial
>    capabilities' criteria.
>
> However, there are also still a lot of blank space in the handbook, mostly
> regarding what kind of support a successful applicant can get.
> It is still unclear if a successful applicant will be able to access to
> these support:
>
>    - An ASP training program (Pending Board consideration of the
>    community’s supplemental policy recommendation (17.2)
>    - Access to Application Counselors (Pending Board consideration of the
>    community’s supplemental policy recommendation(17.2)
>    - A [50-85%] reduction in New gTLD Program application and evaluation
>    fees [which fees TBC]
>    - A [bid credit or multiplier- TBD pending research results] applied
>    to supported applicants participating in an ICANN Auction.
>    - Reduced or waived base Registry Operator fees, should the supported
>    applicant prevailing the gTLD program valuation and proceed to contracting
>    and delegation. (Pending Board consideration of the community’s
>    supplemental policy recommendation (17.2)
>
>
> I was actually surprised to see the last one as I remember it didn't make
> it to the SubPro final recommendations. I do recall a recent GAC advice
> about this though, so probably that's why.
>
> One thing I found interesting was that they strongly advise the applicant
> against revealing the strings they intend to apply when applying for
> applicant support. I don't know if this was the same for the last round. I
> was not particularly convinced by the reasons given in the Handbook and am
> curious of what you guys think.
>
> Another noticeable change is that the applicant will be evaluated on a
> pass/fail basis according to required criteria (public responsibility due
> diligence, financial need, and financial stability). This is very different
> from the scoring methods from the last round.
>
>
> Some observations, happy to hear what others think (:
>
>
> Best,
> Manju
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