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Response to other public comment comments

  • To: public-comment-enhancements-ii@xxxxxxxxx
  • Subject: Response to other public comment comments
  • From: Kieren McCarthy <kierenmccarthy@xxxxxxxxx>
  • Date: Mon, 17 Oct 2011 10:45:02 -0700

Only by accident do I notice the reply cycle period on the ICANN blog, so I
would say there is a clear need to set up a system where those that have
commented are informed of when the reply cycle starts in order to make it
more effective.

I would like to give strong support to both the CADNA and IPC responses:
 msg00008 and msg00006, and general support to the registries response


All noted that the current suggested categories are too ICANN-focussed and
specialized. The IPC provided a list of suggested alternatives. I have
compared this with a list I also suggested and given it some thought and
have prepared what I think is a pretty good combined list that should cover
almost all ICANN public comment periods under categories that make sense to
the general user. The list is at the bottom of this email.


With regard to prioritization, everyone urged ICANN not to dismiss the idea
and I agree. I think CADNA's suggestion that a user and star-based system is
the best suggestion as it encourages interaction and overcomes many of the
suggested pitfalls about staff making decisions. At the same time, both the
IPC and Registries suggested that additional tags would be useful,
highlighting either groups that would likely be interested or the stage
which a comment period is currently in.

These are both good suggestions, although neither recognise that some
comment periods are simply more important and some simply less important
than others. So long as ICANN continues to throw out dozens of comment
periods every year, it is vital that the organization find a way to allow
people to quickly and easily identify which are relevant to them.

Reply cycle

All three - CADNA, IPC and the Registries - say the 15-day reply cycle
should be extended. I agree. Perhaps you could have two settings: a 15-day
response period for when there are few or short responses, and a 30-day one
for when there are many or complex responses.


I agree with the IPC's suggestion that people be required to register to
send a comment. The reality however is that people will want the ability to
respond anonymously. So I would suggest that people have to register but
that they will able to click on a box and choose to post anonymously. I do
think that ICANN has a right to see where comments are coming from (I am
assuming a high level of professionalism on the part of ICANN staff here,
and greater levels of trust than currently exist), but also people will ask
for the right to make a comment without having to make their identity

If you were to include a user-rating system, then people can make up their
minds about a comment's value, regardless of whether it is delivered
anonymous or not.

Technical improvements

Everyone thinks that threaded discussions would be an advance - and I agree.
This comment for example will appear in a single list with everything else.
A threaded discussion would enable me and others to respond to particular

I like the idea (I can't recall who from now) that in the reply cycle that
people have to select which comment there are responding to. This would be a
very effective option I think if you could set it up technically. It would
allow for comments to be grouped together and it would largely avoid people
using the reply cycle as a way of sending in a new response.

Other notes

* I really think a big hole in this review is the role of staff. The staff
are absolutely crucial to the proper functioning of a public comment period.
You can have the best system in the world but without a standard (and
improved) way of comment periods being managed, the system will always be
flawed. The IPC noted a few issues and made a few good suggestions. I would
*really* like to see ICANN produce a standard operating procedure for
comment periods from the staff perspective and then put that out for
comment. I think it would be hugely beneficial to all.

* The IPC raised the issue of comment periods not being incorporated
effectively into decision-making, quoting one case where the comment period
closed and a Board decision was made the next day - with many of those
making the decision having never seen the public comments. This is far from
the first time this has happened. There really need to be an obligation on
ICANN's part to have - and to explicitly respond - to public comment
summaries before any decisions are made. It should be the case that at the
top of every agenda item are the questions:  what there a comment period on
this? Where is the comment period summary? What in that summary do we agree
and disagree with, and why? Without answers to this questions, the decision
should be deferred. ICANN needs to write this into its processes if comment
periods are going to be taken seriously.

That's it, thanks for the opportunity to input. Here is my suggested topics
list, created by blending a list I created with another from the IPC.

Comment period topic list

* Top Level Domains (generic)

* Top Level Domains (country code)

* Second Level Domains

* Security & Stability

* IP addressing

* Internet governance


* Studies & Reports

* Policy processes

* Events & Conferences

* Accountability & Transparency

* Organizational Review

* Finance

* Development

* Privacy

* Multilingualism & IDNs

* Other

-- ends--

Kieren McCarthy

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