Summary

  • The ccNSO Council does not intend to submit a collective Public Comment on the DNS Abuse Mitigation PDP 1 Initial Report, according to a 31 August notice.
  • Country-code domain managers can comment in their own capacity; the notice also confirms earlier ccNSO participation in the policy work.
  • The consultation remains open until 28 September. Neither operator input nor the absence of a Council submission establishes a common ccTLD position.

A council response is not the only way to contribute

The ccNSO Council plans to leave one institutional voice out of ICANN’s latest consultation on domain-name abuse. The operators whose experience might inform that consultation have not been asked to keep quiet.

In a 31 August message to the Council’s public list, Joke Braeken explained that the Council did not intend to submit a Public Comment because the GNSO policy-development process concerns generic top-level domains, or gTLDs. The message said the ccNSO had participated in the PDP and encouraged interested country-code top-level-domain managers to consider commenting in their own capacity.

That is a statement of intention, not a completed account of what will be filed by the deadline. It is also narrower than withdrawal from the work, opposition to its recommendations or a refusal to address abuse. Those conclusions would contradict the distinction the notice makes between collective comment and continued individual participation.

The proposed obligation has a defined audience

The consultation concerns Associated Domain Checks. The working group was asked to develop an obligation for registrars to investigate other domains associated with a customer account or registrant when at least one domain is found to be engaged in DNS Abuse. Its Initial Report contains eight preliminary recommendations and five implementation guidances. They are proposals under review, not newly effective rules.

Submissions close on 28 September at 23:59 UTC. A summary report is due on 16 October, and the group plans to start reviewing and analysing the comments at ICANN87 in Bali. The guided form asks for an overall summary and allows input on any aspect of the report; respondents need not confine their observations to a prescribed set of narrow answers.

A country-code registry may have useful experience with suspicious registrations, abuse reports or the limits of account-level investigation. Sharing that experience does not make its own namespace subject to the proposed gTLD policy. Conversely, being outside that policy’s scope does not make the experience irrelevant.

The distinction matters because a sound operational lesson can survive a change of institutional setting even when the authority to require it does not. A method may be useful elsewhere without arriving as a binding rule.

Cooperation already has a home

The ccNSO’s DNS Abuse Standing Committee, or DASC, offers an existing model. Its public purpose describes a voluntary forum for exchanging information and practices, open to ccTLD managers beyond the ccNSO’s membership. It expressly says the committee neither develops policy nor acts on behalf of the ccNSO or its members.

A resource library and a discussion list support that exchange. They provide a place to find and question practices without turning every contribution into an instruction to the whole country-code community. The Council’s announced approach to this consultation is consistent with that separation of functions, although the notice does not say DASC made the decision.

The current ICANN Bylaws also distinguish the roles. Article 11.1 gives the GNSO responsibility for developing and recommending substantive gTLD policies. Article 10.1 recognizes ccNSO coordination with other ICANN bodies and voluntary activities such as operational cooperation and best practices. Policies binding ccNSO members by virtue of membership follow the separate conditions in Article 10.4(j), subject to its stated qualifications.

This is not an argument that country-code operators have no policy, contractual or legal obligations. Nor does it establish that the Council is forbidden to comment on a neighbouring process. It describes the limits of the particular process now seeking input.

Expertise need not carry a collective mandate

There is a cost to foregoing a Council submission: reviewers may lack one convenient statement bringing together the community’s concerns. Separate comments can be harder to compare, and operators with more time or staff may find participation easier. Those are risks to consider, not findings about the submissions already received.

There is also a benefit. Differences between operating arrangements can remain visible instead of being compressed into an apparently uniform position. A reviewer can assess an operator’s practical experience on its merits without treating it as consent from every country-code registry.

Lu Heng’s distinction between participation and mandate is helpful here: expertise can inform a decision without authorizing someone to bind another party. That is an editorial lens, not evidence of overreach in this consultation.

The test for the next stage is therefore straightforward. Preserve who offered a lesson, under which operating conditions, and what the working group made of it. If the Council maintains its plan, its missing submission should remain exactly that—not a collective yes, a collective no or proof that country-code operators had nothing useful to say.