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