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<p>All,</p>
<p>I want to throw in my two cents about the comment period. The
comments made during our Montreal meetings, by Jim Prendergast
(excerpted below) and on the list this week make sense. Publishing
a report to the Community that lays out our recommendations -- the
whole picture of what we have developed -- is a strong idea.</p>
<p>Such a comprehensive report will go a long in building
understanding, respect and support for our work -- and sharing it
with the rest of the Community who awaits our results. Such a
comment will provide critical underpinnings for Community-wide
agreement -- and allow us to move forward more quickly to the next
round without delay. <br>
</p>
<p>Now is the perfect time to bring the Community into our circle -
to share our work in its entirety - and the quality of our
recommendations for the next and future rounds. Let's share it all
-- and learn what the GAC and others want to share in return --
while we are still convened and can work together..</p>
<p>Best, Kathy<br>
</p>
On 11/15/2019 10:18 AM, Jim Prendergast wrote:<br>
<blockquote type="cite"
cite="mid:BYAPR18MB280824BBD42B64429C6B332BCA700@BYAPR18MB2808.namprd18.prod.outlook.com">
<p class="MsoNormal">Some specific benefits of a comment period
inclusive of draft final recommendations:</p>
<p class="MsoNormal"> </p>
<p class="MsoNormal">Context – Greg Shatan raised a very good
point about only putting out pieces of the report and that it
doesn’t give the community any sense of context in how they fit
into the larger report. Can someone who is concerned with
applicant support really comment on contention resolution
without knowing what support mechanisms there are for applicants
from underserved regions? As many in the community have not
been following the deliberations of this group, they need the
context to understand how everything works together.</p>
<p class="MsoNormal"> </p>
<p class="MsoNormal">Interdependencies – As several people noted,
our final report will be a rather complex with lots of interplay
between sections. As such, allowing the community the chance to
see how the different pieces fit together will paint a more
comprehensive picture of how this effort will ultimately look.
Without having the entire document to review, it’s impossible to
see the various interdependencies.</p>
<p class="MsoNormal"> </p>
<p class="MsoNormal">Changes vs Status Quo - People will naturally
focus on any changes to the 2012 round we propose because those
are new and different. But I think putting entire set of
proposed final recommendations, including where we recommend no
change (the status quo) is valuable as well in case the Board,
GAC or others are expecting a change to something and we decided
not to make any. Helps avoid those surprises.</p>
<p class="MsoNormal"> </p>
<p class="MsoNormal">CCT-RT – This report, and ICANN’s and
SubPro’s handling of it, is on just about everyone’s radar and
was one of 3 Consensus Advice items in the GAC communique. I
realize we are still finalizing our position on this but given
the high-profile nature of this report, especially in the
context of the DNS abuse discussions, we should be sure that
everyone knows what we will be recommending before it is
finalized. If there is an expectation by the Board, GAC, Org or
the community that we should be doing more, then we need to hear
that now and not after the report is finalized.</p>
<p class="MsoNormal"> </p>
<p class="MsoNormal">Completeness check – having the draft final
recommendations available for comment will help not only this
group, but the Board and Org, spot any potential gaps in our
policy making recommendations. I liken this to having an editor
review a draft before it is sent to the publisher. Are we
missing anything? The ICANN Board and Org do not want to be in
the same position as 2012 when they were forced to make policy
as part of implementation because there were gaps in the
Guidebook and related policies. To date, no one in the WG has
seen the whole picture so it’s important for us to do our own
completeness check.</p>
<p class="MsoNormal"> </p>
<p class="MsoNormal">Process – some people have raised an issue
with whether the initial report was in fact an initial report
according to GNSO guidelines. By putting all the draft final
recommendations out for review, I believe it might satisfy those
who have raised this issue. </p>
<p class="MsoNormal"> </p>
<p class="MsoNormal">Mind the GAC - During the session on Sub Pro
with the GAC, Swiss GAC representative Jorge Cancio made it
clear that GAC wants to see the report before the final
recommendations “crystalize.” This comment period could
accomplish this. Knowing that the GAC now has a “Focal Group” on
Subsequent Rounds will hopefully lead to a more efficient
process where we receive feedback that could help us avoid GAC
advice further down the road. I am more confident in the Sub
Pro WG’s ability to respond to GAC feedback now in a timely
manner than I am with the Board’s ability to deal with GAC
advice in a timely manner later. </p>
<p class="MsoNormal"> </p>
<p class="MsoNormal">I’d rather get the bad news now and not later
– As with GAC advice, I’d want to get concerns from the Board
and Org now and not after this has been sent to them by
Council. We can address any substantive issues now as a group
and avoid having the Council reconstitute this group if the
Board sends the report back with guidance/Instruction. When
Cherine said that the Board would act quickly once they receive
the report from Council, don’t make the mistake of assuming they
will quickly approve something. They could just as easily act
quickly and send it back to us. Then we are really stuck.</p>
<p class="MsoNormal"> </p>
<p class="MsoNormal">New comers – Despite lamentations from the
co-chairs to the GNSO council about newcomers not familiarizing
themselves with the work of the WG, when people raised Sub Pro
issues with the Board either during constituency day or the
Public Forum, the response given by the Board was “get involved
with Sub Pro.” Having a broader comment period allows such
involvement without necessarily disrupting the pace of the work
of the group as a whole. It also allows those of us who have
been working on this the entire time to see a full draft
report. Something we have not seen yet. The initial report was
far from complete and the supplemental was a subset of topics.</p>
</blockquote>
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