Comment period should be extended

[George Kirikos <gkirikos@xxxxxxxxx>]

I wish to go on the record that the comment period (and other ICANN comment 
periods) should be extended.

I'll note that this feeling of "overload" is shared by many in the
ICANN community, who've expressly noted it in other recent comments,
e.g.

http://forum.icann.org/lists/atrt-questions-2010/msg00000.html

"I think that it points out that this comment process is not very
effective." (Alan Greenberg)

http://forum.icann.org/lists/atrt-questions-2010/msg00009.html

"It is clear to us that this public comment process is broken. To the
extent that the purpose of the public comment process is to enhance
the accountability and transparency of ICANN’s decision making
process, it is failing.......(skip)...The first is the sheer volume of
public comment periods.....(skip)....While ICANN decisions have
significant impacts on many organizations and individuals, it is
simply not feasible for almost any organization or individual to keep
up with this pace of public comment activity....(skip)....These facts
may help explain why a large proportion of public comment periods
expire with virtually no substantive comments received. Members of the
public simply cannot keep up with the volume of public comment
opportunities; ...." (Steven J. Metalitz, Coalition for Online
Accountability)

http://forum.icann.org/lists/atrt-questions-2010/msg00012.html

"The public comment period is also a highly ineffective one-way system  for
receiving input that the community has asked for years be improved."
(Kieren McCarthy)

http://forum.icann.org/lists/atrt-questions-2010/msg00025.html

"A prioritisation of the ICANN work and longer time periods for
comments are needed, especially for complex issues. Currently the
workload just before the ICANN meeting is such, that it is clearly
impossible for most members of the community to engage and contribute
efficiently." (J.L. Debecker, ETNO)

http://forum.icann.org/lists/atrt-questions-2010/msg00019.html

"ICANN must provide the community more time for public comment, and
greatly improve and clarify the public comment process itself to allow
for adequate public consideration of its decisions and policy making.
For example, in 2010 alone, there have been two public comment periods
when nearly 20 or more topics have been open for comments
simultaneously." (J. Scott Evans, IPC)

Just to give 5 examples. From people who cannot "vote" for more time
in the "poll" created within the transfer working group as to whether or not to 
extend.
 And those are from folks who actually *commented*,
i.e. we don't get to see all the "demand" from people for more time
who simply gave up, because they didn't have enough time to comment in
this so-called "democratic" process. There's a reason why there's a
saying about the "tyranny of the majority" -- it gives people
something to hide behind, so they can avoid accountability and
responsibility.

Folks *need* more time. When I first raised the issue in May, folks
falsely asserted that it was just not possible. Now that it's clear
that it *is* possible, ample time should be given (and 2 weeks just
isn't enough, either, given all the existing comment periods folks are
dealing with right now, not just my own feeling but those from others
as stated above and elsewhere; if another comment period was extended
by 3 weeks, so should this one, if folks aren't going to accept a
September deadline). The "costs" of extending the comment period are
minimal, compared to the benefits to the community.

As Andrew Jackson said, "One man with courage makes a majority."
That's leadership.


Sincerely,

George Kirikos
http://www.leap.com/