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Re: Phase II of Public Comments Enhancements -- Personal comments

  • To: public-comment-enhancements-ii@xxxxxxxxx
  • Subject: Re: Phase II of Public Comments Enhancements -- Personal comments
  • From: Eric Brunner-Williams <ebw@xxxxxxxxxxxxxxxxxxxx>
  • Date: Fri, 30 Sep 2011 14:57:26 -0400

Some recent comments:

Mine, and also Mikey O'Conner's, after the botched-at-birth HSTLD
final (or phoney) report was published -- comments of this nature are
first and foremost notice that something went terribly wrong in the
notice-and-comment proposed rule making process, and the capture of
the work product, reflecting capture of the working group, appears to
the commenter(s) to have taken place.

Independent of the substantive content of such comments, these "public
comments by working group contributors" are the dead canaries of

The comments of the "Business Stakeholder Group" on the 2nd Milestone
report of the JAS WG -- comments of this nature are pure junk.
Ignoring the vast contradiction between the position articulated by
the authors of that "comment" and the purpose of Resolution 20, the
authors of that "comment" were not excluded from directly contributing
to the work product, and used a public comment period to reject
Resolution 20.

Independent of the substantive content of such comments, and in this
instance there was no substantive content, these "public comments by
working group non-contributors" are not directed at the work product
but at the policy originating bylaws entity.

Junk "public comments" -- there is the obvious spam inserted into the
public record, and gratuitous claims by moral idiots such as the
several from the would-be owner of Africa in the JAS public comments.
The accountability and transparency goals adopted, consistent with the
notice-and-comment requirement, do not require that we reward
misconduct or fail to distinguish between spam and self-promotion and
those comments that actually are on point and thoughtful.

More general observations:

Some issues are inter-related, and the siloing of comments is less
useful than integrated comments -- consider for instance the
relationship between rapid update in the FastFlux PDP and the 240
minute registrar response requirement recently adopted. The common
issue is the tempo of events, the reach of contract, and third
parties, whether NS providers or LEOs.

There is no place in the momentary very specific proposed draft and
public comment call-and-response for first principles, summary, or
overview. There are several series of bits of thing sensed by many
busy hands, and no place for the discussion of the existence or habits
of elephants.

The AT goal may be met, in part, by a journal style publication, an
alternative to the wild playground of CircleID and similar, and the
tightly controlled web content of the corporation.

Clearly a integrative or generalization favoring new media isn't what
"threading" comments or micro-topicalization is likely to achieve, so
whatever the benefits "threading" or micro-silos offer, these forms of
new comments won't produce broad outcomes.

While I see that a taxa might assist some lacking context with issues
and comments, I don't see how it can significantly assist those with
that context, so I'm not in favor of the proposed "stratification",
posed as enhancement #1, question #1.

As my answer to #1 is in the negative, my views on enhancement #1,
question #2, the proposed categories, isn't sought. However, I point
out the absence of "Verisign", the legacy monopoly contract holder, as
a proposed category is peculiar, assuming the original purpose of
transitioning from a monopoly to a competitive regime hasn't yet been

As my answer to enhancement #1, question #1 is in the negative, I also
think that "priority", the subject of enhancement #2, question 1, is
not useful to those who have issue understanding, and is both subject
to misuse by those who have write access to the tags, and misleading
to those who lack issue understanding who may use some anonymous
tagging authority as a substitute for issue understanding.

To respond to the open "other ways that 'priority' could be usefully
introduced" question, enhancement #2, question #2, any policy area
that is the subject matter of a policy-and-technology journal (see
above) has real, not fictive, priority. To borrow from another medium,
putting tags all over the Podunk Daily doesn't have quite the same
effect as noticing that some issue is above the fold on today's Times.

Turning to the comment/reply item, we've had comment/reply for years,
the problem is the timing of most of the comments has slipped, for
good, and bad reasons, to the last working day(s). A rebuttal period
would restore the older dialog-in-comments where errors could be noted
and corrections offered, and the community would have several days to
dissect the last minute rubbish -- a task that staff is usually too
polite to attempt.

So yes on enhancement #3, questions #1 and #2.

No on enhancement #4, question #1. The purpose of pre-registration is
to allow abandonment of the comment venue, allowing any clever robot
or unethical person to dump junk into the venue. Deletion of junk is
an alternative to "minimally invasive" barriers to automata.

Eric Brunner-Williams
Ithaca, NY

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