[CCWG-ACCT] Issues with Providing Public Comments on CCWG-Accountability Proposal

[Matthew Shears]

+ 1 Milton - absolutely!

On 02/12/2015 18:46, Mueller, Milton L wrote:
>
> Greg:
>
> FYI, the survey link worked for me.
>
> Agree that the distinction between comments of Chartering orgs and 
> general public is confusing.
>
> We should have a complete and open public comment period, and then 
> allow the chartering orgs to make up their mind. To my mind, that 
> should be sequential rather than simultaneous, otherwise doubts could 
> be raised about whether the public comment is meaningful.
>
> --MM
>
> *From:*accountability-cross-community-bounces at icann.org 
> [mailto:accountability-cross-community-bounces at icann.org] *On Behalf 
> Of *Greg Shatan
> *Sent:* Wednesday, December 2, 2015 1:34 PM
> *To:* accountability-cross-community at icann.org
> *Subject:* [CCWG-ACCT] Issues with Providing Public Comments on 
> CCWG-Accountability Proposal
>
> All:
>
> Two issues with public comments.  The first is primarily logistical.  
> The second is more fundamental.  Both are frustrating.
>
> First, the "SurveyMonkey" link for the survey to respond to the 
> Proposal is not working.  The link is 
> https://www.surveymonkey.com/r/ccwg-acct-draftproposal and the 
> response is
>
>
>   This webpage is not available
>
> ERR_CONNECTION_TIMED_OUT
>
> In any event, it can be difficult to see all of a survey in advance so 
> that responses can be drafted, reviewed and revised appropriately 
> before being entered  into the survey.  Can a PDF or other version of 
> the entire survey be circulated here and posted on the public comment 
> page as soon as humanly possible, please?
>
> Second, the public comment page at 
> https://www.icann.org/public-comments/draft-ccwg-accountability-proposal-2015-11-30-en has 
> the following statement:
>
> The six Chartering Organizations for the CCWG-Accountability are asked 
> to indicate their support for the recommendations in this proposal. At 
> the same time, public participants not involved with a Chartering 
> Organization are invited to comment on the proposal.
>
> This implies that the public comment period is limited to "public 
> participants not involved with a Chartering Organization."
>
> Does this mean that, for example, the Intellectual Property 
> Constituency is somehow barred from public comment?
>
> Does this also mean that our members, e.g., INTA, are also barred from 
> public comment (since they are "involved" with the GNSO through 
> membership in the IPC)?
>
> Does this also mean that members of our members, e.g., "Company X" (a 
> member of INTA), is barred from public comment (since they are 
> "involved" with the GNSO through INTA's membership in the IPC)?
>
> How about members of the GAC and the ccNSO?  Are all the members 
> barred from commenting as well?
>
> If any of the above are not barred from public comment, will their 
> public comments somehow be discounted because they are involved with a 
> Chartering Organization, thus not "invited" to comment, and also 
> assumed to have another outlet for their comments?
>
> At the very least, it is confusing and off-putting.  At worst, it 
> could have the effect of chasing away potential commenters due to 
> their "involvement" with a Chartering Organization.
>
> Clarification would be most appreciated.
>
> Greg
>
>
>
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-- 

Matthew Shears
Director - Global Internet Policy and Human Rights
Center for Democracy & Technology
mshears at cdt.org
+ 44 771 247 2987



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