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My comment - Was Re: [ga] On the ALAC's Request for Comments

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On Tue, 22 Apr 2003, Vittorio Bertola wrote:

> ...and the things we still have to do (such as getting
> the archival of comments up and running).

Because the apparently is no place for people to view the comments, here's 
what I sent in...


This message contains various items, all of which concern the "Proposed
Criteria and Accreditation Process for At-Large Structures, and Proposed
Guidelines for Regional At-Large Organizations' (RALOs) Memorandum of
Understanding (MOU) with ICANN Draft for Public Comment 9 April 2003".

First: Where is the public posting of the comments?  It appears that it
has not been established.

Without there being public posting of comments *while* the discussion
period is open there is no ability for the development of ideas through
the exchange of ideas.  Without the public being able to see the postings
as they occur the whole idea of informed public comment is crippled, if
not rendered a mockery.

Second: The first point under "Proposed minimum criteria for an At-Large
Structure (ALS)" says "...relates to ICANN's technical management
responsibilities for the Internet's domain name and address system..."

I find this linkage of an ALS to "technical" matters to be disingenuous -
ICANN rarely, if ever, deals with technical matters.  ICANN is primarily a
body that deals with legal, social, economic, and business regulatory
matters that have no meaningful relationship to any technical matter

None of ICANN's other "stakeholders" are obligated to demonstrate that
their concerns or representative organizations arise out of a technical
foundation.  This completely artifical limitation of a "technical"
relationship should not be imposed on those of the internet community or
upon any organizations they chose to represent their views.

Third:  Worthy as many of the criteria are (such as the requirement that
ALS's disclose funding to reveal any conflicts), no similar criteria are
imposed on ICANN's other "stakeholders".  Unless and until such criteria
are imposed equally on all other ICANN "stakeholders" and their
constituent organizations it is unfair to impose these conditions on those
in the internet community or upon any organizations they chose to
represent their views.

		Karl Auerbach
		Elected Director for North America
		Internet Corporation for Assigned Names and Numbers
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