[comments-transfer] Public Comment Period
At the ICANN session in Shanghai, one point was reiterated time and time
again by representatives of the Non-Commercial Constituency -- abbreviated
timelines for public comment are totally unacceptable. In comments put forth
by Norbert Klein, Chun Eung Hwi, Isumi Aizu, and Kathy Kleinman it was made
eminently clear that some participants in the ICANN process require
sufficient time to allow for translation of documents, time to do the
outreach to all the countries of NonCommercial constituency, and time to get
a much better participation. Even the Chair of the GAC insisted upon
notice-and-comment provisions that should last at least one month.
Instead of being responsive to the clearly articulated needs of both the
non-commercial community and the governmental community, the Transfers Task
Force has insulted this community of participants by giving it only one week
to respond to their Final Report. This timeframe is inappropriate and only
serves the needs of those who would railroad a particular proposal. As Elana
Broitman of register.com noted in her earlier comment, "8 days is too short"
(even for a registrar that has no language issues with which to contend). If
a major registrar has to ask the question, "what is a Constituency Impact
Statement?", the Task Force has obviously failed to make the process
understandable and predictable to all parties in this discussion.
Set aside the additional time required. There will certainly be another
Board meeting after the Amsterdam session. There is no reason to place the
convenience of the Task Force ahead of the needs of the public and the
constituencies for a proper amount of time to digest and respond to the
policy recommendations presented in this report.