RE: [council] Comment deadlines

["Chicoine, Caroline" <chicoinc@PeperMartin.com>]

HELLO, ANY NC'rs OUT THERE?????  Kathy initially brought up this request and
I and Harald  have commented.  All of our emails are pasted below for your
convenience.  Can we have other people's insight can we can respond to Mr.
Menge's request since the Jan 10th deadline is next Tuesday!
 
Jonathan, as Chair of WGC, I would also like to get your read on this.
 
Mr. Menge, until and unless I get more feedback, I would not assume that
there will be an extension so you can plan accordingly.
 
Caroline G. Chicoine  
 
 

[KATHY]>[3] Comment Deadlines. For the submission of comments to WG-C, I see
a

>fixed date and time for comments. This time falls midday in the US East

>Coast day and early in the US West Coast day. It means that the majority of

>a business day is lost to those who want to submit at the deadline (as many

>do). It also means that the evening is lost to noncommercial organizations,

>small businesses and individuals, many of whom finalize and submit their

>comments after the business day on their personal time.

> I think we set a bad precedent by imposing a fixed time and deadline for

>comments. In the physical world, such deadlines make sense: as regulatory

>agencies accept paper filings and have staffs that go home at 5:30pm. The

>Names Council has no such physical office, and the comments are being filed

>electronically. Further, deadlines exclude comments, and that is certainly

>not our goal.

 
[CAROLINE] I also agree with eliminating time restrictions from deadlines IN
THE FUTURE since I

suspect that many people participating in this process regardless of their

background (i.e., not only non-commercial organizations, small businesses

and individuals) have full day jobs that require their participation "after

the business day on their personal time."

I personally have no problem applying such a new rule to the current WGC

deadline. However, I simply wish to note that this deadline has been known

by all WGC members well in advance for quite some time (i.e. this was not

the typical fire drill we saw with WGA) and in fact the deadline was

carefully chosen to extend until Jan. 10th in light of the holiday

interruptions. Also, while such a new rule would be only a minor

"extension" of the deadline, I simply point out that WGC does not take

kindly to delays in the process. I received quite a bit of flack for

requesting an extension of the last WGC deadline since it fell right after

the NSI/DOC/ICANN Agreements were released (my reasoning being there was not

enough time to review the Agreements before the deadline in order to

determine whether they affected our position paper). Therefore, for the

minor additional time it would provide, I simply question whether it is

worth the potential "bad press", especially given that the reason for the

request is not a new development. Food for thought.

Caroline

 
[HARALD]

Kathryn,

2 disagreements - I agree with the rest:

Disagreement one: The main purpose of a deadline is to make sure everyone 

knows when the deadline is, so that they get their work done before that 

time. For such a requirement, a date AND time is a very Good Thing.

> In this area of commenting, I would like to hold WIPO up as a good

>precedent. WIPO asked that all comments to its domain name proceeding be

>submitted on a certain day -- no time, just a certain day. This was a fair

>way to handle the issue: it allowed each country to have its full day and

>night to complete comments. If one country gets a few more hours in a day,

>there is no harm. If one country does not get its full hours in a day, I

>believe there is.

Disagreement two: On a round globe, stating "day only" is equivalent to 

stating "day, <somewhere in the world>, 23:59:59". Someone will always be 

disadvantaged by this - if <somewhere> is the +1200 timezone (the latest 

possible interpretation), Japan and Australia get a full working day *more* 

to complete comments than the US West Coast has, by the same logic.

>

> So, I formally request that the comments for the WG-C deadline on 

> January

>10 be changed to include a date only, and no time. This change will make

>the process of comment submission easier for noncommercial groups,

>individuals, and small businesses.

Based on the disagreements above, I request (as an individual; I claim no 

other standing in this case) that the Webpage continue to show a date and 

time (GMT) of last submission on all deadlines it publishes. I have no 

opinion on the best time of day to use.

Harald A

--

Harald Tveit Alvestrand, EDB Maxware, Norway

Harald.Alvestrand@edb.maxware.no <mailto:Harald.Alvestrand@edb.maxware.no> 

 

 

-----Original Message-----
From: Eric.Menge@sba.gov [mailto:Eric.Menge@sba.gov]
Sent: Wednesday, January 05, 2000 5:05 PM
To: council@dnso.org
Cc: weinberg@mail.msen.com; bburr@ntia.doc.gov
Subject: [council] Comment deadlines



Members of the Names Council, 

I am writing to you to explore the possibility of adjusting the WG-C Interim
Report Comment Deadline.  Currently, the deadline is set to close on January
10, 2000, 18:00 CET.  For those parties in the North and South America, this
places the comment deadline from 09:00 to 12:00, which significantly reduces
the ability to work on comments on the 10th.  

I would propose that deadline be adjusted to January 10 at 18:00 in the time
zone that the commenter is in.  This would create a sliding scale on the
globe and give all commenters full use of January 10 to finish comments.
Also, it would not pick an arbitrary time zone (like EST or CET) to use for
the deadline.  A deadline based on the commenters time zone would be a
particular benefit to small businesses and individuals who often must work
on these issues in the evening or spaced out during the day in between other
business.

I would be more than happy to discuss the virtues and flaws of this
suggestion.  If it is too late to consider this option for this deadline, I
would recommend that the Names Council consider it for the next deadline.

Eric Menge 

-- 
Eric Menge 
Office of Advocacy 
U.S. Small Business Administration 
(202) 205-6949; eric.menge@sba.gov 
www.sba.gov/advo