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Is ALAC policy advice always related to ICANN Public Comment? 

ICANN Public Comment proceeding is not the only opportunity for the ALAC to provide policy advice. The ALAC responds to the input requests from GNSO Working Groups and comments on their questionnaires or issue-scoping reports via informal channels. The ALAC also identifies issues important to end users -- such as the Public Interest Commitments topic in the New gTLDs application round -- and submits ‘unsolicited’ policy advice to the ICANN Board.

In those circumstances, the ALAC policy advice does not always take the form of the Policy Advice Statement. It can be short-form correspondence sent by the ALAC Chair on behalf of the ALAC. It can also be long-form documents, such as the White Paper on Future Challenges “Making ICANN Relevant, Responsive and Respected” and the Second At-Large Summit (ATLAS II) Declaration.