October 2015 - Accountability-Cross-Community

Update from Brussels
by Mathieu Weill Oct. 12, 2015

Oct. 12, 2015

Dear colleagues, Along with some European members and participants of our group, I am attending the CENTR meeting in Brussels. This morning was a joint session with the European High Level Internet Governance group (made of european GAC representives), and it discussed the IANA Stewardship transition. The outcome of this meeting is summarized in the statement that is now online : https://t.co/EuolALNkgV You can also find my update regarding our work on our wiki (feel free to re-use) : https://community.icann.org/display/acctcrosscomm/CENTR+Accountability+Upda… As part of the discussion, I have noted a suggestion by Roelof that we prepare a short, understandable paper to summarize the state of play, and what remains to be done. Best, -- ***************************** Mathieu WEILL AFNIC - directeur général Tél: +33 1 39 30 83 06 mathieu.weill(a)afnic.fr Twitter : @mathieuweill *****************************

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Memo on Default Judgment and Arbitration
by Gregory, Holly Oct. 12, 2015

Oct. 12, 2015

Dear Co-chairs and CCWG Members and Participants, Attached please find our memo in response to the certified question regarding Default Judgment and Arbitration for distribution and posting. Warm regards, Holly and Rosemary HOLLY J. GREGORY Partner and Co-Chair Global Corporate Governance & Executive Compensation Practice Sidley Austin LLP +1 212 839 5853 holly.gregory(a)sidley.com<mailto:holly.gregory@sidley.com> **************************************************************************************************** This e-mail is sent by a law firm and may contain information that is privileged or confidential. If you are not the intended recipient, please delete the e-mail and any attachments and notify us immediately. ****************************************************************************************************

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Blog post - Hopes for Dublin
by Jordan Carter Oct. 12, 2015

Oct. 12, 2015

Hi all I'm pretty optimistic about what we can achieve in Dublin starting Friday. I've set out why in a blog post which I copy below. A tidy PDF version is attached. Hope you are feeling optimistic too, and are planning to participate in the push to consensus. As ever, look forward to your feedback. cheers, Jordan *Hopes for Dublin* 12 October 2015 Online: https://internetnz.nz/blog/hopes-dublin *As the 54th ICANN Meeting in Dublin approaches, CCWG-Accountability member and InternetNZ Chief Executive Jordan Carter sets out his hopes for the meeting, and his firm conviction that a path to consensus and speedy resolution of the accountability debate is open – and should be grabbed.* It’s crunch time. In Dublin starting this Friday, a significant test faces the Internet community and ICANN. A real opportunity is there for consensus to emerge around a solid plan for improvements to ICANN’s accountability. These are improvements that would see the completion of the accountability framework for ICANN's stewardship of the IANA functions (alongside what is in place for the other communities (numbers and protocols)). Making that happen is going to require everyone to be flexible. That's a challenge, but an achievable one. By way of context, the CCWG is one of the two tracks of the IANA Stewardship transition, together with the ICG. Both are working to make ICANN an effective steward of the Internet's domain name system and a responsible, secure & reliable operator of the IANA Functions for the three operational communities (names, numbers and protocols). The CCWG's working method has been a multistakeholder one, in keeping with how the Internet community makes policy best. After starting work at the end of 2014, the CCWG released a first draft proposal for how to improve ICANN's accountability in May, and a second in August. Since public comments on the second draft proposal closed a month ago, the CCWG has been analysing the feedback offered by the community, and has also spent time in a side effort to understand the logic behind the Board’s counter-proposal. In parallel, as has been the case after each moment of public feedback, CCWG participants have been thinking through how to take the proposal to the next level – taking the feedback into account, clarifying the proposal, thinking about how to change and improve things for a final effort at a proposal that can be tested for consensus. Compared with the most recent draft, here are some key changes that are part of the discussion that could lead to a new synthesis: · A consensus approach for decisions about using the new community powers proposed by the CCWG (replacing the voting-based system) · Much clearer explanation of how the reserve powers the CCWG has been dealing with fit into and build on existing ICANN processes (particularly the importance of consultation and collaboration *before* community powers come into play) · The replacement of a membership model with a designator model (which would reduce the direct enforceability of some of the community powers, but would guarantee that board/director removals and bylaws change approvals were beyond question – and which arguably is consistent with how ICANN operates today) · A commitment to continuous improvement of ICANN’s accountability (including perhaps through a longer-term governance review) · Retention of the basic framework of improved review and redress through a stronger IRP, fundamental bylaws and so on The above synthesis gives all key parties some wins: the basic framework of the CCWG’s work would be intact, the model of multistakeholder policy development upheld, many of the Board’s concerns taken into account, and no significant delays added to slow the transition down. Legal advisors and CCWG members have been fleshing out this approach, ready for discussion on Friday. It seems to me that it would be viable to complete a proposal along these lines and have it out for public comment before the end of the year, and SO/AC approval early in 2016. That’s probably the fastest possible, without putting at risk the quality of the proposal. And since we’ve done that twice, and caused confusion and concern by skimping time to get the proposal clear and readable, it isn’t sensible to make the same mistake a third time. To me that looks like an outcome worth trying very hard for – and if we can manage it, an outcome to be very happy with. As ever, there are some risks. · Some participants have started throwing bottom lines around. Those participants need to back off that, otherwise the chances of a consensus being achievable become very small. · There may be a temptation for the ICANN Board to “box the CCWG in”, trying to monster it or the community into adopting a proposal that doesn’t meet the community’s accountability requirements in the name of timeliness. (In a separate post[1] <#_ftn1> I have already pointed out that it is ICANN that is responsible for the time pressure, so the irony of an approach like this would be rich.) · The technical communities – numbers and protocols – could lose confidence that this accountability process, which is best seen as a "catch up" for names to attain accountability as good as protocols and numbers already have - will ever conclude. Yet if it doesn't, the accountability framework for the IANA functions would be incomplete. This in turn could risk the integrity of ICANN and its role as the IANA Functions Operator for the three communities. · The ICANN leadership could make a mistake with the Dublin meeting, and try to repeat the failed pressure tactics it tried with the CCWG in September (on calls and in Los Angeles) – to put it politely, such an approach would be sure to backfire and reduce the chance of consensus being reached. The bigger picture regarding risk here, which plays on my mind a lot, has to do with the fact that the world’s eyes are on us. If the ICANN community cannot arrive at a consensus for accountability improvements, the chances are that the IANA Stewardship transition will be unnecessarily delayed – possibly not even being complete by 30 September 2016. A further delay (and it would only be a delay – the cat is out of the bag, and the transition is inevitable – it’s only a question of when) would have a stack of downsides. It would embolden critics of the multistakeholder model. It would annoy and exasperate the technical communities, risking the effort to have a single IANA Functions Operator serving all three communities. It would be a red light for Congress in paying very close attention to what is going on. It would be an admission that the players in the ICANN environment can’t reach consensus on an important issue – not a great advertisement for a model that is premised on achieving consensus as its main strength in legitimately coordinating the Internet’s system of unique identifiers. High stakes for all of us. It’s reasonable to have some optimism about the chances of a consensus emerging. Nobody’s interests are compromised by the sort of synthesis the CCWG is working on. As we count down the days to Dublin, let’s recommit ourselves to building an accountability settlement that works. Let’s remind ourselves that consensus and being flexible isn’t about “losing” anything and doesn’t have to be about second-bests. It really can be a collaborative, open process that brings all of us to a better place. Idealistic? I don’t think so: it’s why I support ICANN, it’s why I support the transition, and it’s why I want us to succeed this week and next. It’s a model that works. Let’s use it. That’s my hope for Dublin – a hope I welcome you to share and to turn into reality. Jordan Carter jordan(a)internetnz.nz ------------------------------ [1] <#_ftnref1> See https://internetnz.nz/blog/icann-accountability-chronology-and-dublin-thoug…

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Attention: Bounce Message
by Grace Abuhamad Oct. 12, 2015

Oct. 12, 2015

Dear all, We are not sure what exactly has happened, but many of you received notices that your mailing list subscription was disabled due to excessive bounces. The email¹s subject line looked like "confirm 1838070deaccaa120cde1c6801fcd58cd324e54f². We have reported the issue to our IT team and will get back to you shortly with the remedy. In the meantime, we will add all of you back to the list (we were notified automatically of the disabled accounts, so you should not need to email us). Thank you, Staff team

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Timeline scenarios - initial draft for comments
by Mathieu Weill Oct. 12, 2015

Oct. 12, 2015

Dear colleagues, The co-chairs had tasked staff to highlight what would be a plausible timeline scenario after our group agrees on a proposed way forward in Dublin. We investigated a scenario where we would not need a public comment, as a well as a scenario where an extra pûblic comment would be needed. The attached slides present an initial draft which we submit for comments from the group. In summary, in the absence of an extra PC period, we could deliver the final report on Nov 20 to the chartering organisations at the earliest. If we need an extra public comment, delivery would be around end of january - beginning of february 2016. Best regards, Mathieu PS: a PDF version will be circulated shortly

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Where do we stand? (Was Re: Blog post on the Accountability work headed to Dublin)
by Seun Ojedeji Oct. 11, 2015

Oct. 11, 2015

Dear Co-Chairs, FWIW, I think at this point, it will be good to have an understanding of where we are heading from the Co-Chairs. In some discussions it seem we have understood and agreed that a model that implies a structural change is impractical during this transition phase hence the suggestion made by Steve. Yet in other discussions it seem we are going ahead with the structural change model irrespective of the concerns raised from parts of the community and board. In other to prepare towards Dublin and contribute in a meaningful way, I think a summary of where we are presently and what is expected to be achieved in Dublin will be helpful. I apologise if this has already been shared, and in that case a pointer will be appreciated. Regards Sent from my Asus Zenfone2 Kindly excuse brevity and typos. On 10 Oct 2015 19:37, "Stephen Deerhake" <sdeerhake(a)nic.as> wrote: > Paul, > > Perhaps the Board chair is articulating a minority viewpoint? Afterall, > the > Board will have to vote on the matter of sending/not sending the output of > the CCWG on to NTIA. > > Stephen Deerhake > > -----Original Message----- > From: accountability-cross-community-bounces(a)icann.org > [mailto:accountability-cross-community-bounces@icann.org] On Behalf Of > Paul > Rosenzweig > Sent: Saturday, October 10, 2015 6:05 AM > To: 'Bruce Tonkin' <Bruce.Tonkin(a)melbourneit.com.au>; 'Accountability > Cross > Community' <accountability-cross-community(a)icann.org> > Subject: Re: [CCWG-ACCT] Blog post on the Accountability work headed to > Dublin > > With respect Bruce, I share Anne's view that this is not accurate. The > Board chair has stated unequivocally that the Board will not submit a > Membership based proposal. That is contrary to the statement that the > Board > will submit any proposal it receives from the CCWG "as is." That is > categorically ruling out one type of "as is" proposal. > > If you are seriously telling me that even after all this back and forth the > Board actually would submit a "Membership only" based proposal to the NTIA > then I would respectfully say that the Board has done a very poor job of > communicating. > > So ... answer this question please as directly as you are willing: If, > today, the CCWG having considered but declined to accept the Board's input > were to submit a proposal based upon a Membership organization would the > Board transmit it to the NTIA as the ICANN proposal? > > Paul > > Paul Rosenzweig > paul.rosenzweig(a)redbranchconsulting.com > O: +1 (202) 547-0660 > M: +1 (202) 329-9650 > VOIP: +1 (202) 738-1739 > Skype: paul.rosenzweig1066 > Link to my PGP Key > > > -----Original Message----- > From: Bruce Tonkin [mailto:Bruce.Tonkin@melbourneit.com.au] > Sent: Friday, October 9, 2015 10:03 PM > To: 'Accountability Cross Community' > <accountability-cross-community(a)icann.org> > Subject: Re: [CCWG-ACCT] Blog post on the Accountability work headed to > Dublin > > Hello Paul, > > Regarding: > > https://www.icann.org/news/announcement-3-2015-02-12-en > > The statement still holds. > > The Board has provided input on a draft document so far, and has stated all > along that it would raise any concerns along the way and not wait for a > final proposal to raise any concerns. > > Regards, > Bruce Tonkin > > > _______________________________________________ > Accountability-Cross-Community mailing list > Accountability-Cross-Community(a)icann.org > https://mm.icann.org/mailman/listinfo/accountability-cross-community > > _______________________________________________ > Accountability-Cross-Community mailing list > Accountability-Cross-Community(a)icann.org > https://mm.icann.org/mailman/listinfo/accountability-cross-community > > _______________________________________________ > Accountability-Cross-Community mailing list > Accountability-Cross-Community(a)icann.org > https://mm.icann.org/mailman/listinfo/accountability-cross-community >

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Blog post on the Accountability work headed to Dublin
by Jordan Carter Oct. 10, 2015

Oct. 10, 2015

Hi all, Apologies for the interruption to your inbox. I've been doing a bit of work trying to make sense of all the events in the ICANN accountability debate. I wrote up a chronology of that, which is available attached to this post. A blog post with my reflections is below. Whatever part of the community you are from, and whatever your view on the substance of the debates we are having in the CCWG, I hope you can stand up in support of the multistakeholder model at this challenging moment. There is a lot at stake if this accountability effort fails, and the risk of that is not high but it is increasing. See many of you in Dublin next week! cheers Jordan ICANN Accountability - the chronology and Dublin thoughts 9 October - at https://internetnz.nz/blog/icann-accountability-chronology-and-dublin-thoug… You’ve probably had an experience in your life of being part of a difficult or complicated project – sometimes things go into a blur, or after months or years you find it hard to remember the order of significant events. Well, the debate regarding ICANN’s accountability is nothing if not complicated (not to say difficult!). I’ve been a participant in it as a member of the Working Group representing country-code domains since December 2014, and even over not quite a year, things get a bit blurry. To help me, and possibly you, I decided to pull together a short chronology of some of the key milestones. Dates of proposals, significant moments in the project, and so on. You can review (and critique) the chronology here: .pdf <https://internetnz.nz/sites/default/files/2015-10-09-ICANN-accty-chrono.pdf> .docx <https://internetnz.nz/sites/default/files/2015-10-09-ICANN-accty-chrono.docx> I didn’t expect that seeing this story in one short place would trigger some new insights, or remind me of some old ones, but it did. Here are some of them: - *Astonishing progress:* since the end of last year, and the demise of ICANN’s resistance to a community-led accountability process, the Cross Community Working Group (CCWG) has made huge progress. It assessed previous suggested accountability mechanisms; built requirements for a new settlement; devised models that could deliver; took feedback in good faith and worked together to overcome problems exposed in public debate. The Second Draft Proposal of the group is workable, though it does not enjoy consensus in the ICANN community yet. - *Consistent resistance and delay:* the powers-that-be at ICANN have resisted community-driven accountability reforms throughout this process. The multi-month delay to establishing the CCWG speaks volumes. The group’s work would have concluded next week in Dublin if we’d had the few more months back in 2014. I say that not to lament it, but to make it clear where responsibility lies for the current time pressure. Hint: the CCWG isn’t responsible. - *The rightness of multistakeholderism: *the community has followed a true multistakeholder process. Compromise, diligence, thoroughness and a willingness to compromise and think outside the box – all these have been central to the work of the group. That work process is hard to maintain and has been seriously challenged by the ICANN Board alleging a right to insert “red lines” into part of the debate – on the critical matters of enforcement. Those interventions place the credibility of the multistakeholder process at risk. In doing so, the ICANN Board isn’t only putting the accountability reform process under pressure it doesn’t need, it is delaying the group’s ability to complete its task (others have more forceful views - see the note by William Currie, an Advisor to the CCWG appointed by the Public Experts Group last year, here <http://mm.icann.org/pipermail/accountability-cross-community/2015-October/0…>). The follow on consequence: the IANA Stewardship transition itself is delayed, a consequence only a very few people would celebrate (and I am not one of them). - *Proof of need:* looking over the short history of the current debate gives ample evidence of why the reforms demanded by the community are required. Without the spur provided by the IANA Stewardship transition, this opportunity would never have opened up. We should be grateful to the Obama administration for the chance provided to build a long term, responsible framework for ICANN accountability. - *Some welcome flexibility:* a year ago, if you’d thought you would hear ICANN saying it would welcome binding arbitration, the ability to remove Board directors, a community right of veto in bylaws changes – many would have stared at you and laughed. If you’d suggested a community group working in open multistakeholder ways could deliver a work output the quality the CCWG has matched, the same stares and laughs. But both have happened. Things have moved. Everyone involved with or watching this process will have different insights, or may agree happily or disagree sharply with mine. I offer them up in public as part of my own commitment to accountability: it is reasonable for people involved in the conversation to share their thinking. In any case, my own thought processes work best with dialogue – not with solitude. ICANN is on the verge of historic, meaningful and positive reform. The Numbers and Protocols communities, watching this process through gritted teeth and very keen for the transition to go ahead, can hopefully celebrate what is happening. With ICANN having a curious dual role for the Names community (policy forum and IANA functions operator), there has been no alternative to making accountability improvements now. (To my technical community friends - if there’s any doubt in your mind about why we need change – review the chronology, remember the pushback, remember what you guys faced early this year.) We’re all close to the end of the debate. You can sense it – proposals are crystallising, timeframes are compressing, volunteers are at the end of reasonable commitments of time and energy. The imperatives now are to see things through: to stick with the multistakeholder process that listens to all perspectives but gives nobody a right of veto; the accountability framework the community requires to accept the transition going ahead; and the changes to ICANN’s culture that will flow from a new accountability settlement. Dublin is a week away. The elephant in the room (the CCWG’s proposal and the ICANN Board’s counterproposal for the way to crystallise accountability powers) will need to be resolved, or eaten, or thrown in the ocean. My preference is of course for the product of the multistakeholder process, the model the CCWG has developed in public and with the involvement of all stakeholders. But unlike some others, I am not proclaiming bottom lines on any of the “how” – it is the “what,” the requirements and ability to meet them, that matter. The “what” is ensuring the Internet community, able to organise through ICANN’s open groupings, can hold a corporation with hundreds of staff, hundreds of millions of dollars, tight links with the American government, a monopoly ability to extract rents from the domain name industry, and a natural institutional desire to be as free of restraint as it can – can hold all that to account, given the huge imbalance of power, knowledge, resources that tilt the playing field of accountability entirely in ICANN’s favour. Beyond the "elephant," there are lots of other details that need to be sorted out. It all matters – NTIA have been clear the proposal has to be bullet proof. In the end though, if there isn’t an accountability settlement that achieves consensus, then there isn’t going to be a proposal bullet proof or not. No accountability proposal – no IANA Stewardship Transition proposal. No transition proposal – no transition. No transition? All those risks the transition is designed to head off come back to life. And the multistakeholder approach discredited to boot. Those are the stakes on the table as we head to Dublin. Two final thoughts: where there’s a will there’s a way. And as an old high-school teacher used to say to me, “not easy, not optional.” -- Jordan Carter Chief Executive *InternetNZ* +64-4-495-2118 (office) | +64-21-442-649 (mob) Email: jordan(a)internetnz.net.nz Skype: jordancarter Web: www.internetnz.nz *A better world through a better Internet *

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Cruz / NTIA: Time to Get Expert Advice
by Edward Morris Oct. 10, 2015

Oct. 10, 2015

Hello everybody, Some of the unknowns facing this group going forward are as much political in nature as they are substantive or procedural. Do we take the opinion and perspective of Senator Ted Cruz seriously? Is it a threat to the transition? Is there something that we can do to be responsive to the genuine concerns of Senator Cruz? Are his concerns genuine? What about the NTIA? The deference shown to Secretary Strickling among some of us here is almost Papal in nature. What did Larry say, how did Larry say it, what did he really mean when he said it but really didn't say it. It's a bit ridiculous. I admire Secretary Strickling. He's a fine civil servant. His published salary, though, is less than that of a first year associate from a decent law school at a mid sized corporate law firm. He is not the all mighty. Commerce and the NTIA are complex places. Larry has absolute control of neither. I've read here today a legal analysis of the Senator's Constitutional challenge by someone I know to be neither an American nor a lawyer. I can click both boxes and I have my views but am I sure I'm right? No. It seems everyone here has an opinion as to what the NTIA will or will not accept from us. Do any of us really know? No. Prior to the Los Angeles meeting it was suggested that we might want to hear from ICANN's lobbyists, that they could explain to us their version of political reality. We properly rejected that offer. I think we've reached the point, though, where we do need to call upon the expertise of some Washington political professionals to help guide us through this part of the process. No more guesswork by amateurs or implied threats by those with some self-interest in the matter. We're talking about who is going to run a vital part of the most powerful communications technology in human history. We need to do this right. Fortunately, we've already retained two such individuals who, if we wish, have the expertise and ability to assist us in this area. Back in the early days of this project when we were all young, innocent and hopeful :) we retained not one but two law firms to help guide us. In retrospect that decision and two firms we chose to hire were amongst the best decisions we've made in this CCWG. I have complete faith in our lawyers and that is a rarity for me. I note that one of the specific reasons we hired Sidley was for their Washington ties and expertise. During our interviews with the firm we were able to meet two of their professionals with the greatest knowledge of DC and government operations : Cam Kerry ( http://www.sidley.com/people/cameron-f-kerry) and Rick Boucher ( http://www.sidley.com/people/rick-boucher ). Both men were extremely impressive. It is time to tap their talents. We need serious advice in these areas from serious professionals. I would respectfully ask our Chairs and the full CCWG to consider inviting either Rick or Cam to Dublin to meet with the CCWG early in the week, preferably during the initial F2F. I think it's important that everyone has a chance to question them. We need this type of policy expertise from a politically astute professional who owes a duty of care to us, no one else, and whose rolodex allows him or her to reach out to those whose decisions will most impact our work. We need to know what political reality is if we are to maximise our potential as a very special and unique group dedicated to helping create a truly open and accountable governance mechanism for this small part of the networked world. Thanks for considering. Best, Ed Morris

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Re: [CCWG-ACCT] Comparison of independent review processes
by Samantha Eisner Oct. 10, 2015

Oct. 10, 2015

I am forwarding this on behalf of Jones Day, as they do not have sending rights to this list. Note from Jones Day: Dear CCWG, As Holly noted in her cover email, CCWG Counsel's "Comparison of Independent Review Processes" was provided to Jones Day in advance of it being circulated to the CCWG. In the interests of transparency, please note that Jones Day did not provide line edits identifying the areas of disagreement with CCWG Counsel, but instead provided the attached memorandum for CCWG Counsel's consideration. CCWG Counsel did not revise its Comparison document to reflect the thoughts set forth in the attached Jones Day memo. Sidley/Adler understood that this memo would be shared with the CCWG after their Comparison document was circulated. From: <accountability-cross-community-bounces(a)icann.org<mailto:accountability-cross-community-bounces@icann.org>> on behalf of "Gregory, Holly" <holly.gregory(a)sidley.com<mailto:holly.gregory@sidley.com>> Date: Wednesday, October 7, 2015 at 10:24 PM To: Thomas Rickert <thomas(a)rickert.net<mailto:thomas@rickert.net>>, Mathieu Weill <mathieu.weill(a)afnic.fr<mailto:mathieu.weill@afnic.fr>>, León Sánchez Ambía <leonfelipe(a)sanchez.mx<mailto:leonfelipe@sanchez.mx>> Cc: Sidley ICANN CCWG <sidleyicannccwg(a)sidley.com<mailto:sidleyicannccwg@sidley.com>>, ACCT-Staff <acct-staff(a)icann.org<mailto:acct-staff@icann.org>>, ICANN-Adler <ICANN(a)adlercolvin.com<mailto:ICANN@adlercolvin.com>>, "accountability-cross-community(a)icann.org<mailto:accountability-cross-community@icann.org>" <accountability-cross-community(a)icann.org<mailto:accountability-cross-community@icann.org>> Subject: [CCWG-ACCT] Comparison of independent review processes Dear CCWG Co-chairs, Members and Participants, Attached please find a comparison of key characteristics of (1) ICANN's current IRP, (2) the IRP under the CCWG 2nd Draft Proposal (in the context of the Community Mechanism as Sole Member Model), and (3) the IRP and MEM set forth in the Board Proposal as requested in L.A. We shared this with Jones Day and ICANN Legal in advance so that they could provide any corrections regarding our understanding of the IRP and MEM as set forth in the Board Proposal. Kind regards, Holly and Rosemary Sent with Good (www.good.com) ________________________________ From: Grapsas, Rebecca Sent: Wednesday, October 07, 2015 11:45:50 PM To: Gregory, Holly Subject: **************************************************************************************************** This e-mail is sent by a law firm and may contain information that is privileged or confidential. If you are not the intended recipient, please delete the e-mail and any attachments and notify us immediately. ****************************************************************************************************

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Re: [CCWG-ACCT] Blog post on the Accountability work headed to Dublin
by Bruce Tonkin Oct. 10, 2015

Oct. 10, 2015

I note back in February we did state: " ICANN is expecting to receive both proposals at roughly the same time." I would assume it is still preferable if the two proposals are submitted together. I know we are all still hoping to complete the CCWG work soon. I guess if after Dublin it is clear that the work will take longer, than we could certainly issue an updated statement on timing. My assumption is that the community generally would prefer that both proposals be submitted to NTIA together rather than sending one this year, and another some months later? Regards, Bruce Tonkin

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