Comments on Module 1 -- Volume, time to process, and root zone change capacity
The Staff comments at 1-5, express an expectation that the initial evaluation will be completed in a period of approximately 5 months, and an expectation that this period will increase by 1-3 months if the number of applications is in the range of 400. While useful, this model of application capacity processing is not informed by the Root Scaling Study, which suggests that there exists a limiting factor at the delegation step, which is significantly less than the conservative (sub 400) estimate of initial evaluation capacity, demand, and therefore processing time. If the technical community suggests to ICANN that some smaller number, and for the purposes of this note, I'll use 100, as the number of changes in the root zone per year the technical community thinks prudent at this time, then it would be useful to the applicants to reflect this "back-end" processing limitation" on the earlier processing stages, up to the initial evaluation at 1-5, and the administrative completeness check at 1-4. It would inform the applicant who may not otherwise be informed, that independent of how applications are processed, that no more than 100 applications will result in delegations in first year(s), and that while adequate forward progress may occur in the non-terminal steps of the evaluation process, on average, absent any policy to establish priority, if there are 400 applicants, that the application will wait for 24 months after all non-terminal steps of the evaluation process are complete, and a quarter of all applicants will wait 36 to 48 months after the the evaluation process are complete before their delegation can be processed. The information need not be as detailed as the comments I've circulated, but a rule of thumb for applicants, on the order of "every additional hundred means an additional year to completely process" would be useful, and of course is controlling on the notion that there will be subsequent rounds, and how the disparity between application production and its surplus and delegation production as the scarce resource. As always, in an individual capacity, though I'm employed by CORE which has an interest in the subject matter. Eric Brunner-Williams |