<div>Hello all,</div>
<div><br></div>
<div>So I worked at ICANN for a number of years and a big part of my focus was on improving the public comment periods.</div>
<div><br></div>
<div>I don't see anything wrong with ICANN staff shortening a comment period *if* they are held accountable for that decision.</div>
<div><br></div>
<div>It should be the general manager of Public Participation and one other relevant senior staffer. And they should be named. That is accountability.</div>
<div><br></div>
<div>If they make that decision without communicating sufficiently with the community, then their names are on it and they can be told in no uncertain terms that it was not appropriate. </div>
<div><br></div>
<div>That will cause them to communicate in future and then we don't create yet another process within a process.</div>
<div><br></div>
<div>ICANN staff should be allowed to take responsibility and the community can provide that by tying it with accountability.</div>
<div><br></div>
<div>There's an opportunity here for real improvement rather than teeth gnashing.</div>
<div><br></div>
<div><br></div>
<div>Kieren</div>
<div><br></div>
<div class="mailbox_signature">
<br>-<br>[sent through phone]</div>
<br><br><div class="gmail_quote"><p>On Wed, May 6, 2015 at 8:03 AM, Paul Rosenzweig <span dir="ltr"><<a href="mailto:paul.rosenzweig@redbranchconsulting.com" target="_blank">paul.rosenzweig@redbranchconsulting.com</a>></span> wrote:<br></p><blockquote class="gmail_quote" style="margin:0 0 0 .8ex;border-left:1px #ccc solid;padding-left:1ex;"><p>I agree with David and, inferentially, with Dr. Lisse (a rare moment). The
<br>foundation of accountability for an organization lies in two interrelated
<br>requirements -- first that the organization have rules in place that allow
<br>for it to be held accountable and second that the organization itself not be
<br>in a position to derogate from those accountability rules whatever they are.
<br><br>Here, the accountability comes in the form of a public comment period that
<br>is to be held open for a specified period of time. The derogation comes in
<br>the ability to shorten that time period and thereby reduce the opportunity
<br>for the accountability mechanism to function effectively. I have no
<br>objection, in principle, to allowing for a comment period to be shortened --
<br>when, for example, some emergency requires it or, on the other end of the
<br>spectrum when there are no public comments forthcoming because the proposal
<br>is completely uncontroversial. But it should be axiomatic that the
<br>authority to modify an accountability measure should NOT lie with those who
<br>are being held accountable. It is especially ironic that in this instance
<br>the lack of accountability goes to the comment period on enhancing
<br>accountability -- but I would think that staff should not have this power,
<br>no matter what the subject matter of the public comment is ...
<br><br>Paul
<br><br>Paul Rosenzweig
<br>paul.rosenzweig@redbranchconsulting.com
<br>O: +1 (202) 547-0660
<br>M: +1 (202) 329-9650
<br>VOIP: +1 (202) 738-1739
<br>Skype: paul.rosenzweig1066
<br><br><br>-----Original Message-----
<br>From: David Post [mailto:david.g.post@gmail.com]
<br>Sent: Wednesday, May 6, 2015 10:19 AM
<br>To: Roelof Meijer
<br>Cc: ccNSO Members; CCWG Accountability; directors@omadhina.net;
<br>cctldworld@icann.org; J. William Semich; ccTLD Community List
<br>Subject: Re: [CCWG-ACCT] [ccnso-members] about the CCWG 30-day comment
<br>period
<br><br><br><br>It's a good reminder of why ICANN needs better accountability mechanisms . .
<br>.
<br><br>>The public comment announcement includes the remark "Because this
<br>>(first) Public Comment period is less than the required 40-day minimum,
<br>>it has been approved by two ICANN Global Leaders." The term Global
<br>>Leaders is a reference to senior members of the ICANN staff and the
<br>>condition was created to ensure that a check existed so that a single
<br>>ICANN department would not depart from the standard default time period
<br>>without broader senior staff input. The public comment guidelines and
<br>>procedures are available on the public wiki
<br>>https://community.icann.org/pages/viewpage.action?pageId=48344695
<br><br><br>ICANN staff are not a sufficient check on other ICANN staff - it's pretty
<br>simple. ICANN staff work for ICANN, obviously, and are, obviously, beholden
<br>to it (s they should be, as employees). They will do - or try to do - what
<br>they ultimately think the corporation (i.e., the
<br>Board) wants, because their jobs are dependent on that. There's absolutely
<br>nothing wrong with that
<br>- but to think of it as a "check" on pressure to depart from the required
<br>40-day comment period is pretty deeply flawed.
<br><br>David
<br><br><br><br><br>At 09:18 AM 5/6/2015, Roelof Meijer wrote:
<br>>I am wondering: when Adam writes ³we² our group seems to think he means
<br>>³ICANN staff².
<br>>I do not think ICANN staff has set our time table. I read Adam¹s "You
<br>>will remember this has been our intention since we discussed planning
<br>>in Istanbul, and we concluded this discussion on the CCWG call of 30
<br>>April.² as us, the CCWG, deciding on it.
<br>>
<br>>Completely off-topic, but so ridiculous that I cannot help myself: if
<br>>ICANN senior staff are now described as ³ICANN GlobalLeaders², what
<br>>would that make its CEO? ICANN Leader of the Universe? OMG...
<br>>
<br>>Cheers,
<br>>
<br>>Roelof
<br>>
<br>>
<br>>
<br>>
<br>>On 06-05-15 00:04, "J. William Semich" <bill@nunames.nu> wrote:
<br>>
<br>> >
<br>> >I agree with Dr. Lisse 100%.
<br>> >
<br>> >ICANN staff must not set the timetables for any consensus process.
<br>> >Nor should any committee (co-)chairs.
<br>> >
<br>> >Regards,
<br>> >
<br>> >Bill Semich
<br>> >.NU Domain
<br>> >
<br>> >On May 5, 2015, at 5:11 PM, Dr Eberhard W Lisse <el@lisse.NA> wrote:
<br>> >
<br>> >>
<br>> >> So,
<br>> >>
<br>> >> now ICANN staff decides what comment period is acceptable.
<br>> >>
<br>> >> Outrageously unacceptable and objected to.
<br>> >>
<br>> >> I am still waiting for the response to my request to be provided
<br>> >>with the notes or emails where this was discussed and approved by the
<br>CCWG.
<br>> >>
<br>> >> el
<br>> >>
<br>> >> --
<br>> >> Sent from Dr Lisse's iPad mini
<br>> >>
<br>> >>> On May 5, 2015, at 21:41, Adam Peake <adam.peake@icann.org> wrote:
<br>> >>>
<br>> >>> Note on behalf of Thomas, Leon and Mathieu about the CCWG proposal
<br>> >>>30-day public comment period.
<br>> >>>
<br>> >>> Hi everyone,
<br>> >>>
<br>> >>> We have seen comments about the 30-day public comment period. You
<br>> >>>will remember this has been our intention since we discussed
<br>> >>>planning in Istanbul, and we concluded this discussion on the CCWG
<br>> >>>call of 30 April.
<br>> >>> The outcome was to propose the first public comment should be for
<br>> >>>30 days, which would allow time for us to prepare a response for
<br>> >>>the ICANN meeting in Buenos Aires. It is particularly important
<br>> >>>that we are able to respond to the dependencies identified by the
<br>> >>>CWG-Stewardship.
<br>> >>>
<br>> >>> Recognizing that the shorter public comment is not ideal for a
<br>> >>>subject of such importance to the community, we also took into
<br>> >>>account the fact that we will to hold a second public comment
<br>> >>>period some weeks after ICANN53 when we will seek input on any
<br>> >>>outstanding issues and provide details and explanation prompted by
<br>> >>>discussions with the community from the first public comment and
<br>> >>>during ICANN53.
<br>> >>>
<br>> >>> The public comment announcement includes the remark "Because this
<br>> >>>(first)
<br>> >>> Public Comment period is less than the required 40-day minimum, it
<br>> >>>has been approved by two ICANN Global Leaders." The term Global
<br>> >>>Leaders is a reference to senior members of the ICANN staff and
<br>> >>>the condition was created to ensure that a check existed so that a
<br>> >>>single ICANN department would not depart from the standard default
<br>> >>>time period without broader senior staff input. The public
<br>> >>>comment guidelines and procedures are available on the public wiki
<br>> >>> https://community.icann.org/pages/viewpage.action?pageId=48344695
<br>> >>>
<br>> >>> Warm regards,
<br>> >>>
<br>> >>> Thomas, Leon and Mathieu
<br>> >>> CCWG co-chairs
<br>> >>> _______________________________________________
<br>> >>> Accountability-Cross-Community mailing list
<br>> >>> Accountability-Cross-Community@icann.org
<br>> >>> https://mm.icann.org/mailman/listinfo/accountability-cross-communi
<br>> >>> ty
<br>> >>
<br>> >
<br>> >
<br>>
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<br></p></blockquote></div><br>