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

Wed Dec 2 21:40:04 UTC 2015

What is the point in sending in public comments if the chartering organizations making the decision won’t even have seen them yet?  The chartering organizations are supposed to consider the comments submitted in the public comment period *before* they decide whether to go ahead.  We need to hear from the wider community — and non-English speakers won’t even have the translations until the end of the comment period, and thus be able to read the recommendations for the 1st time.  How can CO's be “deciding” before non-English speakers can even read and respond to the recommendations?  We need to do this in the proper order for our own process to be “accountable”.

Thanks,
Robin

> On Dec 2, 2015, at 1:08 PM, Matthew Shears <mshears at cdt.org> wrote:
> 
> + 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> [mailto: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 <mailto: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>https://www.surveymonkey.com/r/ccwg-acct-draftproposal <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 <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 <mailto:mshears at cdt.org>
> + 44 771 247 2987 
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