Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

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Name: Sarah Wyld
Date: 29 Sep 2025
Affiliation: Tucows
Summary of Submission

Tucows thanks the Standing Committee and their leadership team as well as ICANN Org for their work on this important Report. 

Tucows supports many of the SC's recommendations, as well as the SC's determination that adoption of EPDP Phase 2 SSAD recommendations is not in the best interest of the ICANN community or ICANN and termination of SSAD proof of concept.

The RDRS pilot project has successfully demonstrated that building the SSAD is not financially feasible and is not in the best interests of the DNS or the ICANN Community. If the RDRS is to be maintained, Tucows would only support continued operation of the RDRS as a cost-recovery system that is wholly voluntary for registrars.