Hi Robin,
Perhaps this is an area in which ALAC and NCSG may find common ground.
The ALAC has generally found that the PICDRP, as proposed, does not at all serve the public interest. It is designed to allow monied interests to complain about other monied interests, but otherwise is no remedy to anyone else.
Here is the ALAC statement on the first draft proposal. Unfortunately, not much has changed between then and now. IMO the process is heavily weighted against whistleblowers, advocates and anyone else -- without a direct FINANCIAL interest -- who is impacted by a registry's changing its own rules in mid-stream.
ALAC is planning to make another statement to the Board on this issue, largely reiterating the public-interest deficiencies which have not been addressed since the first iteration. A joint effort would be useful if the NCSG finds common ground with us on this.
- Evan