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

[Mueller, Milton L]

Have the chairs responded to these reasonable, indeed essential, suggestions by Mr. Deerhake?
--MM


From: Stephen Deerhake [mailto:sdeerhake at nic.as]
Sent: Thursday, December 3, 2015 1:26 PM
To: 'Greg Shatan' <gregshatanipc at gmail.com<mailto:gregshatanipc at gmail.com>>
Cc: directors at omadhina.net<mailto:directors at omadhina.net>; accountability-cross-community at icann.org<mailto:accountability-cross-community at icann.org>
Subject: Re: [CCWG-ACCT] Issues with Providing Public Comments on CCWG-Accountability Proposal

Greg,

In my view the way out of this is as follows:

1. The co-chairs recognize that the 30 November CCWG Accountability Proposal is a new proposal (which it is, having undergone the model change since the prior proposal), and thus should be afforded a proper, full-length public comment period as per ICANN policy.  As has been noted in other posts, PROCESS is important, and the abbreviated comment period set by the co-chairs is a violation of accepted process.

2. Upon conclusion of the full length public comment period, Staff reviews, categorizes, and summarizes the comments, as they did admirably at the conclusion of the comment period for the prior proposal.  Their work is published for the Community and SO/AC's benefit.

3. A reasonable period of time subsequent to the publication of the Staff report on the comments received be allotted to the SO/AC's to consider the current proposal in light of (a) their having had sufficient time to read and understand the proposal, (b) sufficient time to consider what the public commentators stated about the proposal, and (c) sufficient time to confer with their membership about the proposal (and in the case of the ccNSO, this means both ccNSO members and non-ccNSO ccTLDs).

Short of following accepted procedure, this process is tainted, perhaps fatally.  The shortened public comment period (particularly with regards to the time allotted to non-English speakers who will have only 3-4 days to comment by the time the translations are complete) is a joke.  It's worse than a joke actually.  It's giving the middle finger to the entire ICANN multi-stakeholder process, because what it is saying is "yes, we will respect established procedures and policies, except when we don’t want to."  This is unmitigated nonsense.  There is no compelling reason to shorten the public comment period, to demand that the SO/AC's consider and weigh in on the Proposal before the comment period has closed.

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