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

Mon Apr 20 18:14:03 UTC 2020

Hi Kathy, Claudio, Paul T., All,

I’m writing to add my voice to the chorus of folks asking for an extension.  We can’t pretend that transformation of work and life that we are all going through will not affect the timeframe in which we can all turn this around.  If we remain diligent in the home stretch, we can make up the time lost.  I support a modest extension so that everyone feels they have had their chance to speak on these important topics.

Best,
Paul

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From: GNSO-RPM-WG <gnso-rpm-wg-bounces at icann.org> On Behalf Of claudio di gangi
Sent: Monday, April 20, 2020 7:57 AM
To: Paul Tattersfield <gpmgroup at gmail.com>
Cc: gnso-rpm-wg <gnso-rpm-wg at icann.org>
Subject: Re: [GNSO-RPM-WG] Comment deadline 4/27 - question

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<mailto: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<mailto: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<mailto: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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