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(*) Comments submitted after the posted Close Date/Time are not guaranteed to be considered in any final summary, analysis, reporting, or decision-making that takes place once this period lapses.

FINAL STATEMENT

The final Statement is to be added here upon completion. 

DRAFT STATEMENT

The PEDNR PDP recommended that information about renewal fees and how a registrar will contact a registrant should be readily made available on the registrar web site (Rec. 5 & 6). It was the clear intent of the recommendations that this apply to ALL registrants.

Paragraphs 4.1 and 4.2 of the ERRP (http://www.icann.org/en/resources/registrars/consensus-policies/errp/draft-policy-11oct12-en.pdf) require, among other things, that if a registrar operates a web site, certain information must be clearly displayed there. Paragraphs 4.1.2 and 4.2.3 require that a reseller, if one is used, must similarly display this information.

It is the understanding of the ALAC that the belief within the PEDNR WG was that all provisions of the RAA that applied to registrars must be enforced by registrars on resellers (for those who use them). Since that has now proven to be false (reference to Greenberg post) it is imperative that sections 4.1.2 and 4.2.3 of the proposed ERRP not be omitted.

The ALAC understands that registrars might be reluctant to include terms that have not been fully vetted during the PDP process, but the two paragraphs in question are identical in impact to the existing 3.12.5 and should have no unforeseen consequences not already in the current RAA.

Without these two paragraphs, there is no obligation for a registrar to ensure that a reseller displays this information and a significant percentage of registrants, those who deal with resellers, may be deprived of this information.  The access to this information that the PDP was attempting to ensure is no longer guaranteed, and the registrar, by subcontracting services to a reseller, has effectively been relieved from fulfilling these RAA obligations. This calls into question the value of the immense time and energy that the community puts into developing PDP Consensus Policy Recommendations and indeed the effectiveness of the entire RAA.