Comment ccNSOAG3:

[Adam Peake <ajp@xxxxxxxxxxxx>]

Thank you for the opportunity to comment, and congratulations on your 
very good work.

The Policy-Development Process you describe seems to work to a quite 
strict timeline. Have you been able to map the activities as a flow 
diagram, showing the time available for each task, the process, and 
resources required for each task? I am wondering what the capacity of 
the PDP might be in terms of the issues the ccNSO could handle 
concurrently, or issues each year (or some other period.)

Section 13, Board Vote. The ICANN Board has a history of near 
unanimous votes, I don't remember an occasion (must have ben one?) 
when they voted anything less than a 66% vote of the board. Given 
this now long history, I wonder if this provision is meaningless? 
(Unfortunately meaningless, normally, it would be sensible.)

How do you expect ICANN's new bylaw commitment to allow the 
Government Advisory Committee power to consider and comment on all 
ICANN Board policy decisions to effect the Board's review of policy 
recommendations from the ccNSO? Quite reasonable to expect that the 
GAC to pay particular attention to policy effecting ccTLDs. Have you 
considered how much time-lag this may introduce to your admirably 
rapid PDP? And how much influence the GAC might have on ccNSO policy. 
See, I think, sections 
<http://www.icann.org/minutes/minutes-appa-31oct02.htm#III-6> and 
various items under 
<http://www.icann.org/minutes/minutes-appa-31oct02.htm#XI-2.1> 
(particularly h. i. j. and k.) of the new bylaws.

Finally, and perhaps I am jumping the gun and this comment should 
wait for a later category (ccNSO member membership, structure or 
Council.)

I hope you will develop a means for public participation in ccNSO PDP 
that is at the very least as robust as that which ICANN is at last 
adopting for its own PDP. While ccTLDs should represent their Local 
Internet Communities and this LIC involvement should include 
opportunities for the public (i.e. registrants) to participate in the 
workings of the ccTLD, most (with a few notable and praise worthy 
exceptions) at best limit the LIC to members who pay, typically ISPs 
or large corporation, while some have little or no interaction with 
anyone. With the ccTLDs departure for the DNSO, the involvement of a 
global community of ccTLD users that might be represented by the 
registrant constituencies (business, non-commercial, even GA and 
intellectual property) has been lost. These entities/voices should be 
present in the new ccNSO PDP structure.

Again, thanks for the chance to comment.

Adam

Adam Peake
GLOCOM Tokyo


--