[comments-transfer] Public Comment Period

[DannyYounger@cs.com]

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.