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Public comment on public comments

  • To: public-comment-enhancements-ii@xxxxxxxxx
  • Subject: Public comment on public comments
  • From: "Mike O'Connor" <mike@xxxxxxxxxx>
  • Date: Thu, 29 Sep 2011 16:29:00 -0500

Hi all,

Sorry this comment is so terse/informal, the deadline is upon me and I don't 
have time to craft a better one.

A few thoughts to add to the discussionā€¦

1) Public comments have multiple "customers" and those customers have different 
needs -- some of which are conflicting.  Here's a quick list of customers that 
comes to mind.  Building a public-comment process that only addresses the needs 
of some of these people is likely to lead to disappointment down the line.

-- The public 

-- Internet users

-- Councils and the Board

-- Constituencies

-- Working groups

-- Staff

2) Here's a quick list of "needs" (mostly speaking from the point of view of a 
working-group type person here)

-- Gain new insights into, and improve analysis of, the problem/puzzle that is 
being analyzed

-- Avoid omissions or mistakes

-- Avoid wasted effort and dead ends

3) There are several kinds of *useful* comments

-- Advance a position that hasn't been discussed already

-- Correct a mistake

-- Broaden an analysis

4) There are *conflicting* logistical issues that need to be considered

-- Constituencies have different (tighter) timing constraints than other 
organizations or individuals, mostly due to the need to review comments 
internally before submitting them.  This conflicts with...

-- Working groups (and the staff who help them).  Most notably working under 
pressure to meet arbitrary deadline dates.  Balancing these timing issues is 
very important, and something we aren't doing very well in some cases.

5) Things to avoid

-- Don't let public comments become a substitute for active participation in 
working groups.  Constituencies need to be especially aware of this -- a 
one-shot public comment isn't very useful if it's written with the goal is a 
radical change to the direction taken by a working group.  That's because the 
consensus-building that's required takes time and conversation if it's going to 
stick.  Yes, that means many hours over many months, many conference calls, 
helping with analysis/writing, all that.  If we depart from that hard-work 
model, we lose the "bottom up consensus" thing that we're all about.

-- Equally unhelpful are public comments that seek to reopen debates that have 
already been discussed to death.  They make people on both sides cranky -- "I'm 
being ignored!" by the people filing the comments, "where were these people 
when we were discussing this?" from working group members.

6) Things to try

-- Take a look at the suggestions that Kieren made in his comment.  I like the 
idea of a dialog around comments rather than just tossing missives over the 

-- Acknowledge that there are conflicts (and sometimes dilemmas) in the 
requirements for public comment.  Please do assemble a group of active 
working-group participants, staff, former chairs, etc. to get their perspective 
on what would be helpful.  Assemble another group -- of constituency leaders -- 
and ask them the same thing.  Look for successful models outside of ICANN.  
It's OK to be a little incremental about this, and iterate quickly toward 
things that improve the situation.

Again, sorry this is so terseā€¦  

Mikey O'Connor (speaking as an individual)

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