Comments on Module 1 -- Volume, time to process, and root zone change capacity

[Eric Brunner-Williams <ebw@xxxxxxxxxxxxxxxxxxxx>]

The Staff comments at 1-5, express an expectation that the initial 
evaluation will be completed in a period of approximately 5 months, 
and an expectation that this period will increase by 1-3 months if the 
number of applications is in the range of 400.
While useful, this model of application capacity processing is not 
informed by the Root Scaling Study, which suggests that there exists a 
limiting factor at the delegation step, which is significantly less 
than the conservative (sub 400) estimate of initial evaluation 
capacity, demand, and therefore processing time.
If the technical community suggests to ICANN that some smaller number, 
and for the purposes of this note, I'll use 100, as the number of 
changes in the root zone per year the technical community thinks 
prudent at this time, then it would be useful to the applicants to 
reflect this "back-end" processing limitation" on the earlier 
processing stages, up to the initial evaluation at 1-5, and the 
administrative completeness check at 1-4.
It would inform the applicant who may not otherwise be informed, that 
independent of how applications are processed, that no more than 100 
applications will result in delegations in first year(s), and that 
while adequate forward progress may occur in the non-terminal steps of 
the evaluation process, on average, absent any policy to establish 
priority, if there are 400 applicants, that the application will wait 
for 24 months after all non-terminal steps of the evaluation process 
are complete, and a quarter of all applicants will wait 36 to 48 
months after the the evaluation process are complete before their 
delegation can be processed.
The information need not be as detailed as the comments I've 
circulated, but a rule of thumb for applicants, on the order of "every 
additional hundred means an additional year to completely process" 
would be useful, and of course is controlling on the notion that there 
will be subsequent rounds, and how the disparity between application 
production and its surplus and delegation production as the scarce 
resource.
As always, in an individual capacity, though I'm employed by CORE 
which has an interest in the subject matter.
Eric Brunner-Williams