Proposal

1. Summary of the Problem being addressed by this Policy Proposal

Policies for managing IP number resources in the AFRINIC service region are created through a Policy Development Process which describes the steps through which policy proposals are submitted, considered, debated and adopted.

1.  The current consolidated policy manual 2016 does not have provision for proposal adoption, which induces duplication of proposals dealing with same problems, lack of clarity of problem statements and proposals out of scope of the PDP. It also does not define clear method for moving proposals forward.
2.  The consensus process for decision-making is not defined, opening doors for interpretations and inactions.
3.  The current PDP does not have provision for board adopting policies as per section 11.4 of the AFRINIC constitution in the varying of the process

 

2. How this proposal addresses the problem

This Policy proposal addresses these issues by:

1. Detailing the consensus process with regard to major and minor objections and responsibility of the Chairs of the working group in gauging the consensus
2. Providing with different phases for policy proposals: from adoption till last call and ratification by the AFRINIC board of Directors
3. Providing provision on how board adopts policy as per section 11.4 of the constitution that is managed in varying the PDP

 

3. Policy Development Process

3.1. Scope

The Policy Development Process covers the development and modification of policies for a proper and responsible usage and management of Internet Number Resources within the AFRINIC service region and is shaped to come up with clear, technically effective and useful policies. Internet number resources consist of Internet Protocol version 4 (IPv4) address space, Internet Protocol version 6 (IPv6) address space, and Autonomous System (AS) numbers. 

1. Policies for Internet number resource management must be evaluated for technical effectiveness against three requirements: conservation, aggregation, and registration.
2. Changes to the Policy Development Process itself will also follow the process.
3. Internet number resource policies are distinctly separate from AFRINIC general business practices and procedures. General business practices and procedures are not within the purview of the Policy Development Process.

 

3.2.  Policy Development Principles

All policies are developed by the Internet community following four principles: openness, transparency, fairness and bottom-up. The Internet community initiates and discusses the policy proposals. If consensus is reached on a given policy proposal, it is recommended to the AFRINIC Board of Directors to be ratified as an effective policy to be implemented within AFRINIC region.

 

3.2.1 Openness

All policies are developed in an open forum in which anyone may participate in. There are no qualifications for participation.

 

3.2.2 Transparency

All aspects of the Policy Development Process are documented and publicly available via the AFRINIC website. The discussions are publicly archived. All procedures that are developed to implement the policy are documented by AFRINIC and are publicly available.

 

3.2.3 Fairness

The policies are to ensure fair distribution of Internet number resources and facilitate the operation of the Internet within AFRINIC Service Region.

 

3.2.4 Bottom-Up

The community drives policy development

 

3.3. Policy development Working Group (PDWG)

The Policy Development Working group (PDWG) provides an open public forum to discuss Internet numbers resources management policies and related topics of interest to AFRINIC and the Internet community in the AFRINIC service region. PDWG sessions are held at AFRINIC Public policy meetings. Between meetings, discussions continue via the Resource Policy discussions mailing list. PDWG is open to all interested individuals.

[The Policy development Working Group guidelines and procedures are defined in a separate document, which is part of the PDP]

 

3.4 Consensus 

Most of the decisions in the working group operations and discussions on policy proposals are made through rough consensus, unless specified otherwise.

In the context of the PDP, “Consensus” refers to “rough consensus” and must be treated as such.

The PDWG consensus process is a multi-stakeholder approach to decision-making. The process is used to develop the best possible resource management policies for the AFRINIC service region.

The consensus process begins when somebody proposes a new policy.

The discussion phase begins on the mailing list and continues during the Public policy meetings.

 

3.4.1 Minor objections

A minor objection is one where the objector believes some problems may occur for some participants in the community if the proposal goes forward. 

The PDWG participants should work together to see if the proposal could be modified to overcome minor objections.

However, it is not always possible to overcome these objections. In this case, the Chairs may ask the objectors if they are prepared to acknowledge that the overall advantages of the proposal outweigh their objections and are willing to set them aside.

 

3.4.2 Major objections

Major objections are serious and indicate a belief that major problems will occur for parts of the community if the proposal goes forward; therefore, the proposal cannot be adopted in its current format.

The Chairs should devote sufficient time for the PDWG to discuss ways to overcome major objections.

PDWG participants, including the proponents, should work together to develop solutions that overcome major objections. 

Consensus is reached on a proposal if the PDWG is able to successfully work through all objections in this way. It is not necessary for everyone to agree with the proposal. ‘Rough consensus’ is the point where all objections have been resolved or given due consideration and the PDWG believes the benefits outweigh the disadvantages.

 

3.4.3 Reaching consensus

In the meeting the Chairs may ask for a show-of-hands, or other techniques, to gauge support for a policy proposal. The use of show-of-hands or other techniques is not a vote. It is a way of broadly measuring opinion and the Chairs’ final decision take many additional factors into account, including earlier discussions on the mailing list.

Consensus is achieved when everyone consents to the decision of the group. The decision may not be everyone’s first preference, but is acceptable to all.

The aim of the PDWG is to carefully consider all opinions before making a decision. 

At the end of a meeting the chairs shall decide if a proposal has gained enough support to move to the concluding phase.

Any major objection to a proposal during the concluding phase must be fully and adequately addressed prior to a determination of consensus. 

Consensus is achieved when everyone consents to the decision of the group. The decision may not be everyone’s first preference, but is acceptable to all.

 

3.5. Policy proposals

Anyone can submit a policy proposal to PDWG Chairs

 

3.5.1 Phases of a policy proposal

A policy proposal follows four phases during its evolution through policy development process: Adoption Phase, Discussion Phase, Review Phase and the Concluding Phase.

 

3.5.1.1 The Adoption Phase

During this phase, the PDWG Chairs will assess the clarity and the relevance of the problem statement in accordance to the scope of the PDP and the existing policies.

PDWG Chairs or AFRINIC staff can work with the initiator(s) to redefine the problem statement if need be. 

For policy proposals which are out of scope of AFRINIC PDP, or addressing the same issue as another policy proposal already adopted, the PDWG Chairs shall dissuade the initiator(s) from submitting to the working group.

In case of disagreement or doubt the PDWG Chairs may consult the working group on whether or not the working group is willing to adopt the proposal for discussion based on its problem statement.

Once adopted by the working group, the initiator(s) grant(s) all rights to the working group and the proposal becomes a community document. 

In all matters of intellectual property rights and procedures, the intention is to benefit the community and the public at large, while respecting the legitimate rights of others. 

Any call for adoption should last minimum of two weeks. At the end  of the call for adoption, considering all the views expressed, PDWG Chairs declare the beginning of the Discussion phase or the rejection of the policy proposal. 

The initiator(s) of the policy proposal can reformulate their problem statement and go back to the adoption phase.

 

3.5.1.2 The Discussion Phase

Once the PDWG Chairs declare the adoption of a policy proposal for discussion, the Discussion Phase begins on the RPD Mailing List (rpd@afrinic.net). The PDWG Chairs should set the period for the Discussion Phase and this must be for at least four weeks.

During the discussion phase, the working group evaluates the policy proposal and comments are made. Politeness and courtesy must lead discussions, PDWG Chairs should emphasize this each time it is relevant.

 

• At the end of the Discussion Phase, the PDWG Chairs provide a summary of the discussion highlighting the close and open issues.
• Once the working group agrees on the summary, which can be edited according to feedbacks, the PDWG Chairs decide whether the policy proposal should move to the next phase (Review Phase), go to an extended discussion phase or should be withdrawn. The decision to move forward will be announced on RPD mailing list. 
• If significant comments or modifications are suggested during the Discussion Phase, the policy proposal initiators will review the proposal and a new version will be published. A new Discussion Phase will then start for the new version of the proposal. This new Discussion Phase should last at least two weeks. 
• If the suggested comments or modifications are not so significant to require a new Discussion Phase, the PDWG Chairs can decide to move the proposal to the next phase (Review Phase) with a new version of the proposal incorporating the necessary changes. 
• Each version of the proposal is publicly archived to transparently show the history of changes to the proposal and published on AFRINIC web site.
• The new version of the policy proposal should be announced on AFRINIC RPD mailing list and website before the proposal can be moved to the Review Phase.
• The PDWG Chairs shall request the AFRINIC Ltd CEO to conduct and publish an impact analysis about the proposal before it can be moved to the Review Phase. The goal of this analysis is to provide relevant supporting information to facilitate the discussions about the proposal and provide some projections about the possible impact if it were to be accepted. This analysis will contain the following points:
  • AFRINIC Ltd’s understanding of the proposed policy
  • Impact on the registry and Internet Number Resources
  • Impact on AFRINIC Ltd’s operations/services
  • Legal impact

 

3.5.1.3 The Review Phase

The goal of this phase is to review the full draft policy proposal compiled at the end of the Discussion Phase. Hence, the final documentation of the proposal will lead to consensus; all modifications made to that document should be transparent to the working group. During the Review Phase, discussion of the draft proposal can continue, also in the light of the impact analysis, and within the context of the proposal, further modifications can still be suggested regarding the draft proposal. The Review Phase should last for a maximum of four weeks. 

1. At the end of the Review Phase, the policy proposal is presented at the next Public Policy meeting.
2. The PDWG Chairs determine whether the proposal has gained enough support to move to concluding phase. If not, the PDWG Chairs can send the draft proposal back to the Discussion Phase if the initiators are willing to make an improvement of their proposal and make the necessary changes according to the feedback received from the community. 
3. A draft proposal sent back to discussion phase automatically lost its status of draft proposal.
4. The PDWG Chairs can also decide to have the draft proposal edited and start a new Review Phase with a new version of the proposal or otherwise the proposal shall be withdrawn.

 

3.5.1.4 The Concluding Phase

In the case, the Chairs determine that the proposal has gained enough support to move to the concluding phase, the PDWG Chairs shall  initiate as soon as possible and not later than two(2) weeks after the Public Policy meeting a "Last Call for Comments" and the Concluding Phase starts. The Last Call period lasts at least two weeks. The Last Call shall be announced on policy discussions mailing list. 

The purpose of this Last Call period is to provide the community with a final opportunity to comment on the draft proposal. This is especially intended for those who missed the previous  phases and want to oppose the proposal or  raise a  major  objection. At this stage, objections need to be justified just as in the other phases for them to be taken into account. 

1. At the end of the Last Call period, the PDWG Chairs will assess the feedback received during this period and decide whether consensus has been achieved. If there is no feedback from the community at this stage, this is regarded as consensus.
2. If consensus is achieved, the PDWG Chairs will announce the decision and initiate the process of the draft proposal ratification by AFRINIC board of directors. 
3. If consensus has not been achieved, the PDWG Chairs can decide to either send back the proposal to the previous phases of Discussion or Review, otherwise the proposal shall be withdrawn. 
4. The initiators of a policy proposal (or anyone else) are free to return the proposal to the RPD mailing list for further discussion after a withdrawal.

 

3.6. Policy Ratification

After a draft proposal has reached consensus, co-chairs shall submit it to the AFRINIC board of Directors for ratification. The submission report shall be comprehensive and provide enough detail about the lifecycle of the proposal through the PDP. 

AFRINIC board of Directors has the obligation to ratify a policy proposal unless:

- The board finds that the PDP process or the declaration of consensus was materially flawed and wishes to remand the proposal to the community for further clarity of the community’s support for it.

- The board in its fiduciary role feels that the proposal would be harmful to the organization in which case the board has a duty to remand the proposal to the community with specific advice on the problematic areas of the proposal and the risks to the organization.

In the case of a rejection, the AFRINIC board of directors must justify and publish the reason on the resources policy discussion list (rpd@afrinic.net) and on the AFRINIC website, and ask the working group to rectify the issue.

After ratification, AFRINIC board of Directors, announce their decision to the working group and this activates implementation of the policy by AFRINIC staff.

 

3.7. Varying the Process

3.7.1 Variance by the PDWG

The process outlined in this document may vary in the case of an emergency. Variance is for use when a one-time waiving of some provision of this document is required. The decision to vary the process is taken by the Working Group Chair. There must be an explanation about why the variance is needed. The discussion, review and concluding period shall not be less than four weeks. If there is consensus, the policy is approved and it must be presented at the next Public Policy Meeting.

 

3.7.2 Variance by the AFRINIC board of Directors

AFRINIC bylaws allows board of Directors to adopt policies regarding the management of Internet number resources where it considers that the same is necessary and urgent, having regard to the proper and responsible usage of these resources.

Such adopted policy must be presented at the following public policy meeting for the working group consideration as per prescriptions of the same bylaws. 

 

3.8. Implementation

The implementation date of the policy is announced on the Resource Policy Discussion mailing list. The implementation date should be less than six months after ratification of the proposal by the board unless a waiver is requested.

 

3.9. Appeals

a. During the adoption and discussion Phases

During the adoption and discussion phases, anyone who has a complaint or other concern about the policy proposal, how it is being handled on the policy development mailing list, how chairs made their decision about the adoption or rejection of a proposal, should first raise the matter with the PDWG Chairs. If the dispute cannot be resolved with the PDWG Chairs, the appeals Procedure can be invoked.

b. During the Review & Concluding Phases

At these stages of the process  complaints should not be about the policy proposal itself unless there are exceptional extenuating circumstances.

Anyone who believes that the proposal has not been handled correctly or that the PDWG Chairs have made an incorrect determination of consensus should first raise the matter with the PDWG Chairs. If the dispute cannot be resolved with the WG Chairs, the Appeals Procedure can be invoked.

 

3.9.1 Appeals procedure

An appeal can only be filed if supported by three (3) individuals from the Working Group who participated in the discussions to the appeal committee.

The appeal must be submitted within two weeks of the chairs’ actions or decisions announced on the Resources Policy Discussions list (rpd@afrinic.net) or during a Public policy meeting.

The Appeal Committee shall issue a report on its review of the complaint to the Working Group in maximum 4 weeks after the appeal is recorded, unless a waiver is requested. 

The Appeal Committee may direct that the Chairs decision be annulled if the Policy Development Process has not been followed. The appeal committee decision is final

  

3.9.2 Appeal committee

The AFRINIC Board of Directors shall appoint an appeal committee to handle appeals and disputes, which may arise in this Policy development process.

 

4.0 Acknowledgements

This proposal is mainly based on the intensive discussions we had on the current PDP during 2016 and 2017 on RPD mailing list. It addresses the issues by referring to best practices from IETF and the PDP of other RIRs.

 

Revision History

Revision History 

Date	Revision
28 Apr 2017	Version 1 AFPUB-2017-GEN-002-DRAFT-01
09 Nov 2017	Version 2 AFPUB-2017-GEN-002-DRAFT-02 - Addresses most of the staff and Legal concerns: Adds a section on implementation Removes restrictions on the board varying the PDP Clarifies deadlines to appeal against chair decisions - Amends the appeals procedures - Splits the proposal in two documents: a. The PDP b. Working Group guidelines and procedures. - Changing to the working group chairmanship to 2 chairs.
28 Apr 2018	Version 3 AFPUB-2017-GEN-002-DRAFT-03   3.4 Consensus Clarify “Consensus” in the context of the PDP. Refers to “Rough Consensus”. The document  made consistent with “consensus”   3.5. Policy proposals Clarify the process of selecting document editor.   3.6. Policy Ratification Clarify how board acts for the ratification or not of a proposal submitted by the Working group.   3.7.2 Variance by the AFRINIC board of Directors Clarify PDP variance by Board and remove referral to bylaws sections   3.8. Implementation Fix the mistake for implementation counter to start with the ratification by board and not  from last call consensus date.
29 October 2018	Version 4 AFPUB-2017-GEN-002-DRAFT-04   3.4.3 Reaching Consensus: Chairs are given up to 2 weeks to make decision of a draft proposal presented at PPM or at end of adoption phase of a proposal   3.5 policy proposals: - Remove possibility of author’s anonymity - Remove option for chairs to serve as document editor   3.9.2 Appeal committee: Add provision for board appointed appeal committee as in current PDP
09 June 2019	Version 5 AFPUB-2017-GEN-002-DRAFT-05   - Typos and grammatical errors fixed   Old version (4) New Version (5) 3.4.3 Reaching consensus In the meeting the Chairs may ask for a show-of-hands, or other techniques, to gauge support for a policy proposal. The use of show-of-hands or other techniques is not a vote. It is a way of broadly measuring opinion and the Chairs’ final decision take many additional factors into account, including earlier discussions on the mailing list. The aim of the PDWG is to carefully consider all opinions before making a decision. At the end of meeting or after the adoption phase of a policy proposal, the Chairs will decide if the working group has reached consensus within 2 weeks. Consensus is achieved when everyone consents to the decision of the group. The decision may not be everyone’s first preference, but is acceptable to all.  3.4.3 Reaching consensus In the meeting the Chairs may ask for a show-of-hands, or other techniques, to gauge support for a policy proposal. The use of show-of-hands or other techniques is not a vote. It is a way of broadly measuring opinion and the Chairs’ final decision take many additional factors into account, including earlier discussions on the mailing list. Consensus is achieved when everyone consents to the decision of the group. The decision may not be everyone’s first preference, but is acceptable to all.  The aim of the PDWG is to carefully consider all opinions before making a decision.  At the end of a meeting the chairs shall decide if a proposal has gained enough support to move to the concluding phase. Any major objection to a proposal during the concluding phase must be fully and adequately addressed prior to a determination of consensus. Consensus is achieved when everyone consents to the decision of the group. The decision may not be everyone’s first preference, but is acceptable to all. 3.5.1.1 The Adoption Phase During this phase, the PDWG Chairs will assess the clarity and the relevance of the problem statement in accordance to the scope of the PDP and the existing policies. PDWG Chairs or AFRINIC staff can work with the initiator(s) to redefine the problem statement if need be. For policy proposals which are out of scope of AFRINIC PDP, or addressing the same issue as another policy proposal already adopted, the PDWG Chairs shall dissuade the initiator(s) from submitting to the working group. In case of disagreement or doubt the PDWG Chairs may consult the working group on whether or not the working group is willing to adopt the proposal for discussion based on its problem statement. Once adopted by the working group, the initiator(s) grant(s) all rights to the working group and the proposal becomes a community document. In all matters of intellectual property rights and procedures, the intention is to benefit the community and the public at large, while respecting the legitimate rights of others. Any call for adoption should last maximum of two weeks. At the term of two weeks, based on consensus, PDWG Chairs declare the beginning of the Discussion phase or declares the rejection of the policy proposal. The initiator(s) of the policy proposal can reformulate their problem statement and go back to the adoption phase.  3.5.1.1 The Adoption Phase During this phase, the PDWG Chairs will assess the clarity and the relevance of the problem statement in accordance to the scope of the PDP and the existing policies. PDWG Chairs or AFRINIC staff can work with the initiator(s) to redefine the problem statement if need be. For policy proposals which are out of scope of AFRINIC PDP, or addressing the same issue as another policy proposal already adopted, the PDWG Chairs shall dissuade the initiator(s) from submitting to the working group. In case of disagreement or doubt the PDWG Chairs may consult the working group on whether or not the working group is willing to adopt the proposal for discussion based on its problem statement. Once adopted by the working group, the initiator(s) grant(s) all rights to the working group and the proposal becomes a community document. In all matters of intellectual property rights and procedures, the intention is to benefit the community and the public at large, while respecting the legitimate rights of others. Any call for adoption should last minimum of two weeks. At the end  of the call for adoption, considering all the views expressed, PDWG Chairs declare the beginning of the Discussion phase or the rejection of the policy proposal. The initiator(s) of the policy proposal can reformulate their problem statement and go back to the adoption phase. 3.5.1.3 The Review Phase The goal of this phase is to review the full draft policy proposal compiled at the end of the Discussion Phase. Hence, the final documentation of the proposal will lead to consensus; all modifications made to that document should be transparent to the working group. During the Review Phase, discussion of the draft proposal can continue, also in the light of the impact analysis, and within the context of the proposal, further modifications can still be suggested regarding the draft proposal. The Review Phase should last for a maximum of four weeks. 5.At the end of the Review Phase, the policy proposal is presented at the next Public Policy meeting. 6.The PDWG Chairs determine whether the working group has reached consensus. In the case the PDWG Chairs decide that consensus has not been reached, then the PDWG Chairs can send the draft proposal back to the Discussion Phase if the initiators are willing to make an improvement of their proposal and make the necessary changes according to the feedback received from the community. 7.A draft proposal sent back to discussion phase automatically lost its status of draft proposal. 8.The PDWG Chairs can also decide to have the draft proposal edited and start a new Review Phase with a new version of the proposal or otherwise the proposal shall be withdrawn.  3.5.1.3 The Review Phase The goal of this phase is to review the full draft policy proposal compiled at the end of the Discussion Phase. Hence, the final documentation of the proposal will lead to consensus; all modifications made to that document should be transparent to the working group. During the Review Phase, discussion of the draft proposal can continue, also in the light of the impact analysis, and within the context of the proposal, further modifications can still be suggested regarding the draft proposal. The Review Phase should last for a maximum of four weeks. e. At the end of the Review Phase, the policy proposal is presented at the next Public Policy meeting. f. The PDWG Chairs determine whether the proposal has gained enough support to move to concluding phase. If not, the PDWG Chairs can send the draft proposal back to the Discussion Phase if the initiators are willing to make an improvement of their proposal and make the necessary changes according to the feedback received from the community. g.  A draft proposal sent back to discussion phase automatically lost its status of draft proposal. h.  The PDWG Chairs can also decide to have the draft proposal edited and start a new Review Phase with a new version of the proposal or otherwise the proposal shall be withdrawn. 3.5.1.4 The Concluding Phase In the case, the Chairs determine that the WG has reached consensus at the end of the Review Phase, the PDWG Chairs move the draft proposal to a "Last Call for Comments" and the Concluding Phase starts. The Last Call period lasts at least two weeks. The Last Call shall be announced on policy discussions mailing list. The purpose of this Last Call period is to provide the community with a final opportunity to comment on the draft proposal. This is especially intended for those who missed the previous two phases and want to oppose the proposal or make substantial remark. The "Last Call for Comments" gives time to the community after the PDWG Chairs declare at the end of the Review Phase so that suggestions for any final changes or objections to the proposal can be sent to the WG mailing list. At this stage, objections need to be justified just as in the other phases for them to be taken into account. 5.At the end of the Last Call period, the PDWG Chairs will assess the feedback received during this period and decide whether consensus has been achieved. If there is no feedback from the community at this stage, this is regarded as consensus. 6.If consensus is achieved, the PDWG Chairs will announce the decision and initiate the process of the draft proposal ratification by AFRINIC board of directors. 7.If consensus has not been achieved, the PDWG Chairs can decide to either send back the proposal to the previous phases of Discussion or Review, otherwise the proposal shall be withdrawn. 8.The initiators of a policy proposal (or anyone else) are free to return the proposal to the RPD mailing list for further discussion after a withdrawal. 3.5.1.4 The Concluding Phase  In the case, the Chairs determine that the proposal has gained enough support to move to the concluding phase, the PDWG Chairs shall  initiate as soon as possible and not later than two(2) weeks after the Public Policy meeting a "Last Call for Comments" and the Concluding Phase starts. The Last Call period lasts at least two weeks. The Last Call shall be announced on policy discussions mailing list.  The purpose of this Last Call period is to provide the community with a final opportunity to comment on the draft proposal. This is especially intended for those who missed the previous  phases and want to oppose the proposal or  raise a  major  objection. At this stage, objections need to be justified just as in the other phases for them to be taken into account. e.  At the end of the Last Call period, the PDWG Chairs will assess the feedback received during this period and decide whether consensus has been achieved.  If there is no feedback from the community at this stage, this is regarded as consensus. f.  If consensus is achieved, the PDWG Chairs will announce the decision and initiate the process of the draft proposal ratification by AFRINIC board of directors. g.  If consensus has not been achieved, the PDWG Chairs can decide to either send back the proposal to the previous phases of Discussion or Review, otherwise the proposal shall be withdrawn.  h.  The initiators of a policy proposal (or anyone else) are free to return the proposal to the RPD mailing list for further discussion after a withdrawal. 3.9. Appeals a. During the Discussion Phase During the Discussion Phase, anyone who has a complaint or other concern about the policy proposal or how it is being handled on the policy development mailing list should first raise the matter with the PDWG Chairs. If the dispute cannot be resolved with the PDWG Chairs, the appeals Procedure can be invoked. 3.9. Appeals a. During the adoption and discussion Phases  During the adoption and discussion phases, anyone who has a complaint or other concern about the policy proposal, how it is being handled on the policy development mailing list, how chairs made their decision about the adoption or rejection of a proposal, should first raise the matter with the PDWG Chairs. If the dispute cannot be resolved with the PDWG Chairs, the appeals Procedure can be invoked. 3.9. Appeals b. During the Review & Concluding Phases At these stages of the process – i.e. after the PDWG Chairs have declared initial consensus or the proposal is in Last Call – complaints should not be about the policy proposal itself unless there are exceptional extenuating circumstances. Anyone who believes that the proposal has not been handled correctly or that the PDWG Chairs have made an incorrect determination of consensus should first raise the matter with the PDWG Chairs. If the dispute cannot be resolved with the WG Chairs, the Appeals Procedure can be invoked. 3.9. Appeals b. During the Review & Concluding Phases At these stages of the process  complaints should not be about the policy proposal itself unless there are exceptional extenuating circumstances. Anyone who believes that the proposal has not been handled correctly or that the PDWG Chairs have made an incorrect determination of consensus should first raise the matter with the PDWG Chairs. If the dispute cannot be resolved with the WG Chairs, the Appeals Procedure can be invoked.