[bc-gnso] Draft BC comment on Proposed New GNSO Policy Development Process

Steve DelBianco sdelbianco at netchoice.org
Fri Mar 25 21:48:00 UTC 2011

ICANN is now gathering public comment on the final report and recommendations by a work team focused on the Policy Development Process (PDP-WT)

Below is a draft for BC comments prepared by Philip Sheppard.

ICANN's Comment period closes 1-April, so today (25-March) begins an abbreviated 7-day review period for these abbreviated comments.

Please review and post your suggestions/edits as soon as possible.   If there are no disagreements noted by 30-March, these comments will be adopted without a voting period, and posted to ICANN on 1-April.

For topic background, see  http://www.icann.org/en/public-comment/#gnso-pdp-final-report

Thanks again to Philip Sheppard for his brief but pointed review of a report that's over 100 pages long.

Thanks also to BC members who served on the PDP work team:
Marilyn Cade
Mike Rodenbaugh
John Berard


DRAFT BC position on Policy Development Process (PDP) Work Team
Proposed Final Report & Recommendations

General Comments
At 109 pages the report is thorough but overly long.

It is a report of a team with recommendations but not yet a guide for prospective participants in a PDP.  As noted in recommendation 3 this work needs to be turned into a short practical manual on the PDP without references to the working team or recommendation number ## or extraneous points of discussion. The start of such a document in section 5 is good but seems overly long at around 15 pages. A rigorous edit is required.

The flow charts are useful but overly complex. A simplified one for council initiated work only is needed. A flowchart showing timelines would be useful.

Comments on specific recommendations

10 and 11. The BC is concerned that the “preliminary issues report” is being over engineered. This report is intended to be short and factual outlining the issue raised NOT solving it or adding opinion on its merit. Therefore an additional public comment period at this stage is both redundant and will waste time.

12. Whereas certain issues will indeed benefit from a workshop, making this a mandatory procedure is short sighted.

13. A possible impact analysis before a vote to start a PDP is an option that will be gamed by parties wishing to delay a new PDP.

16. Codifying a practice to delay seems a dangerous precedent. If done the wording needs to be clear that this is not a cumulative right potentially delaying a decision to launch a PDP by six Council meetings.

Voting thresholds. There is a lot of discussion about Council voting thresholds. The BC recommends further changes to these should simplify not add complexity to an already overly complex structure.

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