Alice,
Thank
you for this. The Heritage Foundation’s opposition to full
GAC participation in the empowered community was not noted
in the Rec 1 analysis. As stated in our comment, we think
that GAC should be strictly advisory.
On
Rec 7 analysis, I’m concerned that our position may be
misunderstood. We support including DIDP in an appeals
process, but we are very much against restricting it to the
engagement, escalation, and enforcement staircase because
that process is dependent on the Empowered Community. DIDP
appeals need to be accessible to everyone, not just the
SOACs, and appeals should not require SOAC approval at any
threshold. This may require moving DIDP appeals to the
request for reconsideration process.
On
Rec 11, the one sentence summary gives the impression that
we support Rec 11. We do not and offered specific proposals
on how to change the text to address our concerns, which
were not included in the Rec 11 analysis.
Best
wishes,
Brett
On
behalf of CCWG-ACCT Co-Chairs
Attached
to this email you will find a staff produced summary and
analysis of the public comments received on our Draft
Proposal.
Please
note that we cannot convert the spreadsheet into a PDF,
the tabs and spreadsheet being too large. Thank you for
your understanding.
