<div dir="ltr"><div class="gmail_default" style="font-family:verdana,sans-serif">This will not be the first time that formatted comments have been used. The IGO/INGO Working Group used a form, as did the Policy & Implementation Working Group. The previous comment period for this group did not use a form, and the task of drawing a report and other useful information from the comments was extremely difficult and time consuming. Public comments are intended to have a utility. This approach will maximize that utility. I support the use of the form.</div><div class="gmail_default" style="font-family:verdana,sans-serif"><br></div><div class="gmail_default" style="font-family:verdana,sans-serif">Just out of curiosity, if there's no database behind the form, what is behind the form? A spreadsheet (a la Google forms)?</div><div class="gmail_default" style="font-family:verdana,sans-serif"><br></div><div class="gmail_default" style="font-family:verdana,sans-serif">Greg Shatan</div></div><div class="gmail_extra"><br><div class="gmail_quote">On Tue, Apr 21, 2015 at 3:43 PM, Andrew Sullivan <span dir="ltr"><<a href="mailto:ajs@anvilwalrusden.com" target="_blank">ajs@anvilwalrusden.com</a>></span> wrote:<br><blockquote class="gmail_quote" style="margin:0 0 0 .8ex;border-left:1px #ccc solid;padding-left:1ex">Hi,<br>
<br>
Having reflected on the proposed form for public comment for a few<br>
more minutes, I think that it should not be used. This is not to deny<br>
the probable utility it would bring. But I think it will itself be a<br>
distraction.<br>
<br>
The community was promised an open CCWG process with the normal ICANN<br>
procedures. As it is, the document is late, the document that gets<br>
posted will have significant gaps (this is a charitable way of saying<br>
"incomplete"), and the normal length of public comment is not going to<br>
be met. If we now add a completely new form that nobody has ever<br>
heard suggested before, people are going to wonder what's being hidden<br>
behind this innovation. (Indeed, several of us seemed to have exactly<br>
that reaction on the call.)<br>
<br>
It would be quite different if the plans to use this mechanism had<br>
been mooted before -- even weeks ago, but ideally in Singapore or<br>
earlier. Without having done that, this will look to those who<br>
mistrust ICANN as yet another way to filter input so that anything<br>
critical doesn't get heard.<br>
<br>
I'm moreover quite sceptical of the technical support behind this.<br>
The existing public comment mechanism uses SMTP (email) and a<br>
confirmation loop before taking that mail and putting it in a public<br>
archive. It's been working for years. On the call, I heard assurance<br>
that there's no database behind the proposed form (which, I note, was<br>
itself not actually complete in time for the call). In my day job for<br>
the past several years I have either designed, developed, or managed<br>
the developers of software. There needs to be some form handling that<br>
will take the input from the form and put it somewhere. This might<br>
not be a relational database, but there is _some_ software, however<br>
trivial, to develop here. This seems like work that would be valuable<br>
to do, but not work that is so valuable that we ought to drop other<br>
things to implement this new feature at the very last second before<br>
public comment should start. If one of my agile development squads<br>
came to me the day before the end of a sprint, and suggested designing<br>
and implementing a completely new mechanism the day before our demo to<br>
the product owner, I'd suggest -- very, very firmly -- that perhaps<br>
that idea belonged in the next sprint. If there is any software<br>
problem at all (I hesitate to use the word "glitch", but perhaps it<br>
will awaken memories for some of you), then it will raise all sorts of<br>
issues about preparation, execution of the task, and so on.<br>
<br>
Therefore, while I agree that this is an innovation that ought to be<br>
pursued, I suggest that it ought to be pursued in the context of a<br>
less fraught issue for a task that has been smoother than this one has<br>
been.<br>
<br>
Best regards,<br>
<br>
A<br>
<span class="HOEnZb"><font color="#888888"><br>
--<br>
Andrew Sullivan<br>
<a href="mailto:ajs@anvilwalrusden.com">ajs@anvilwalrusden.com</a><br>
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