[GNSO-RPM-WG] Comment deadline 4/27 - question

[claudio di gangi]

Paul, all,

I am sympathetic to the concerns expressed here by Paul. To be honest, I
think it raises a flag and justifies due consideration on whether this new
approach is working as intended.

As an initial matter, Paul I noticed that you can send a note to <
policy-staff at icann.org> for assistance on submitting your comments without
having to navigate the online form. It goes unsaid, but it would be very
unfortunate if we did not receive the benefit of your constructive ideas.

>From my perspective, when one reviews that web page, there is a clear
inference (I presume by design) that the online form should be utilized in
most cases. However, it well may be that the challenges of navigating the
form, combined with the complex policy report and the limited amount of
time that is allocated for comment (in comparison to the years of
deliberation that go into producing the work product) create a perfect
storm instead of rainbows and sunshine.

Paul on background, I believe this new approach came about during Phase 1
of the ePDP on the Temp Spec (for Whois), i.e. it was developed/proposed by
the policy support staff team in conjunction with the chair, and then
presented to the full ePDP team somewhat as a fait accompli. From my view,
that group had bigger fish to fry than to analyze the consequences of
relying on this tool going forward for most submissions generally. The
circumstances and extreme time constraints imposed on that expedited PDP
process was unique, and other standard PDPs are not operating under similar
circumstances. That is where my understanding of the history ends, and I
leave it others to fill in the blanks or correct me if I misstated any of
the facts.

If I can take a moment to opine. Sometimes in the process of iteration and
working towards making improvements, the risk arises of missing the forest
for the trees. On that basis, I think it would be prudent for ICANN org to
take a slight pause and consider the impact of this new format on the users
of the system. In particular, with regards to the unaffiliated internet
user, registrant, company, organization, etc. who fall under ICANN's public
interest remit, but who do not have the resources or time to get more
involved, attend phone calls, meetings, and collaborate with other
participants to lighten the load. For these stakeholders, the public
comment process is their sole method of participation, and I think it would
be wise for ICANN to have as the highest priority making the submission of
public comments as simple as possible. Otherwise, the benefits, e.g. saving
resources and generating efficiencies, may be outweighed by a reduction in
participation, transparency and/or accountability. That is how I am reading
Paul's email.

Obviously, the ideal system is one that *encourages* the submission of
public comments. To end on a positive note, the good news is we have a very
dedicated support team with Mary, Julie, Ariel, etc. who care deeply about
the issues and about us as individuals; and the same goes for our fellow
community members, including our leadership team, etc. So I trust in the
end this will get sorted out.

Sorry for the long note on a Monday morning. Hope everyone enjoys their day!

Cheers,
Claudio


On Sun, Apr 19, 2020 at 1:50 PM Paul Tattersfield <gpmgroup at gmail.com>
wrote:

> Hi Kathy,
>
> I’m not sure extending the comment period will help much. Does anyone
> really expect the majority of people to wade through pages of Google forms
> to express an opinion?
>
> I was going to comment on a couple of matters, including making sure IGOs
> have access to the TMCH but even though I have a reasonable working
> knowledge of the report I felt on balance it was too much of a time sink to
> comment substantively.
>
> I did try to read the other comment submitted (which now seems to have
> disappeared) but I couldn’t even access any of the longer fields to read
> all the text. Also I didn’t have the time to waste looking up what each
> answer was in response to as the Google form only has recommendations and
> question numbers so I needed to cross reference everything.
>
> All in all, pretty abysmal to be honest.
>
> I am curious though if it is someone trying to over engineer comment
> periods or whether perhaps it’s more serious such as systemic bias leading
> to complete distain for any input that might be contrary to a predetermined
> outcome?
>
> Best regards,
>
>
> Paul
>
> On Sun, Apr 19, 2020 at 2:45 PM Kathy Kleiman <kathy at kathykleiman.com>
> wrote:
>
>> Hi All,
>>
>> I hope you and your families, firms, organizations and schools are well
>> and safe amidst the COVID19 challenges around the world.
>>
>> Our RPM WG comments are due a week from tomorrow (4/27).  This comes even
>> as other comment and related deadlines are being extended (e.g., USPTO is
>> allowing  documents "due between (and inclusive of) March 27, 2020, and
>> April 30, 2020" to be considered timely if filed "within 30 days of the
>> original due date").
>>
>> How has COVID18 affected the companies and organizations we were hoping
>> to reach with this comment period?  How should we be considering revising
>> deadlines and other filing issues, if at all, in response to the crisis?
>>
>> I would value your input greatly.  The RPM WG Leadership Team is meeting
>> at 9am Eastern tomorrow (Mon) to discuss.
>>
>> Best regards,
>>
>> Kathy Kleiman
>>
>>
>>
>>
>>
>>
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