[council] Proposed Edit to Council Letter to CCWG-ACCT

Phil Corwin psc at vlaw-dc.com
Thu Jan 21 15:08:24 UTC 2016


Fellow Councilors:

I want to suggest a potential edit to our Council letter.

Right now it reads:
We expect that the CCWG-Accountability develop a Supplemental Proposal based on the input from its Chartering Organizations and the public, the GNSO Council expects also that it and other Chartering Organizations, as well as the larger community, will have an adequate opportunity to review and comment on the Proposal in a timely fashion.

My suggested revision would have it read as follows:
We expect that the CCWG-Accountability develop a Supplemental Proposal based on the input from its Chartering Organizations and the public, the GNSO Council expects also that it and other Chartering Organizations, reflecting the larger community, will have an adequate opportunity to review and comment on the Supplemental Proposal in a timely fashion. (changes in Bold)

As the sentence notes via its reference "and the public", we have already had a public comment period on the Third Proposal. The draft language could be read to suggest that we favor another round of public comment on the anticipated Supplemental Proposal, which could prevent NTIA from receiving the Proposal in the timely manner required (delivery by mid-to-late February) that provides a substantial likelihood of completing the transition in 2016.

The proposed revision emphasizes that the Chartering organizations, including the GNSO, are the proper entities to submit any additional comments on the Supplemental Proposal and can transmit the views of their constituents.

I realize that some Councilors may wish to have the Supplemental Proposal subject to another round of public comment. If there is a consensus for that position then I would suggest that any such comment period be limited in duration to reflect the fact that the narrow subject of such comments would be those changes made from the Third draft in response to the recent comment period.

In any event, I believe our letter should be more clear than the present draft regarding the Council's position in regard to whether an additional round of public - as opposed to Chartering Organization - comment is desired on the Supplemental Proposal we expect to see shortly.

Best to all,
Philip


Philip S. Corwin, Founding Principal
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"Luck is the residue of design" -- Branch Rickey

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