Dear Evan: To your second question, the answer's somewhat complex. The voting on the statement was setup specifically so that it would end on the 10th, in order to allow the statement to be sent in before the comment period closed. However, during the voting, Sebastien returned from holidays and raised questions about the statement's content, as he believed that it was to include an addition which he had written and tried to send in to the working group list immediately before he left for the Philippines. Unfortunately the statement didn't reach the list and therefore didn't arrive in the window during which comments were still being taken on the draft before voting began. As a result it was not clear to us precisely what to do. At the same time, we had transmitted the statement, and accompanying draft text of the email to accompany it, to the Excom list so that either one of the Excom, or ourselves on behalf of the ALAC, were to transmit the statement to the public comment period. An answer took a little time. What we (staff) should have done is simply send the statement in once the voting was concluded, copying the relevant lists and people, and asking for forgiveness afterwards as it were, due to the situation. For not ensuring this I apologise. At the same time, were we to have ensured Maria had a copy and knew what the situation was, that would have also helped greatly, though in this particular case the statement text had already been transmitted to the Board as a part of the At-Large Summit Declaration, so the contents had already been seen by the Board. Whilst it was very public that At-Large was going through the bottom-up, community-wide consultation on the text before the ALAC vote to ratify the statement, Maria has many things to read and would have certainly been helped by directly receiving something from us so that she knew what was coming and had the text to hand (apologies to you too Maria). I would not want anyone to think that I'm trying to shift any responsibility to Sebastien or anyone else - I most definitely am not - but I do want you all to understand the situation as a whole. I think that this sort of situation would be much less likely to occur if At-Large's policy advice development process didn't run up so close to deadlines but I would like to stress that I know this is often very difficult to avoid considering the bottom-up nature of deliberation in At-Large that takes place to the maximum extent possible, the geographic and linguistic diversity of participants, and the 30-day window in which many, though not all, comment periods run. In this vein it may interest you to know that Cheryl's asked me to prepare a draft Advisory for the ALAC and community to consider related to the structure of public consultations, drawn from the Thought Paper on the subject requested by Working Group 1 in the lead-up to the Summit. The referenced paper may be found here: https://st.icann.org/data/workspaces/summit-wg/attachments/wg1_documents:200... Evan Leibovitch wrote:

Hello everyone.

ICANN staffer Maria Farrell recently wrote a letter to the ALAC announce list, scolding At-Large for missing one of ICANN's typical too-tight comment deadlines.

In a moment of pique I wrote the response below. Before I send it in my capacity as NARALO chair, I would like to receive feedback on both its content and appropriateness. Personally I'm simply fed up with complaints like this that we can't play the game as well as the vested interests.

And ... to At-Large staff ... are Maria and other ICANN staffers not alterted in advance when ALAC statements are to be submitted past their deadlines? I thought that was the case,

- Evan

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Maria Farrell wrote:

...

In the future, I would be most grateful if you could follow the agreed procedure for submitting public comments to an ICANN consultation; i.e. posting them to the correct location within the time agreed. This is the only way to ensure equity between all contributors and allow us to complete the overall process in a timely manner.

I understand that it can be a challenge for diverse groups to get comments agreed in time. However, other contributors with similar internal consensus-building processes to fulfill, including the GAC, various government authorities and trade associations, submit their input on time and/or appraise the relevant staff beforehand if there is going to be an issue.

Hello Maria,

Respectfully, if the above statement conveys your true sentiment then you do not, indeed, understand At-Large.

At-Large, by definition, does not include bodies with financial interest in ICANN outcomes. It has no business models, national interests, or property to protect. Its members primarily do not have English as their first language, let alone the technical jargon that more often than not pervades ICANN policy debate. They do, however, attempt to represent more than 99% of the community affected by ICANN decisions.

During my brief history within At-Large I have seen countless similar misunderstandings of At-Large's most difficult role within ICANN. These misunderstandings are manifested through unrealistic deadlines, and other expectations that are based on the assumption that we can move as quickly as governments and lobbyists with interests to protect. When was that last time that At-Large was ever consulted in advance on whether a deadline was reasonable?

Some of these misunderstandings, arguably, are institutionalized deep within ICANN. To a casual observer, the idea that ICANN's "public participation" mechanism is distinct and separate from the component that works with At-Large is astounding.

If ICANN claims of public transparency and accountability are to be seen as more than a facade, then perhaps it's time to better recognize -- throughout the organization -- that the challanges of At-Large are both different and substantially more complex than those of governments or vested interests.

Sincerely,

Evan Leibovitch Chair, NARALO

-- -- Regards, Nick Ashton-Hart Director for At-Large Internet Corporation for Assigned Names and Numbers (ICANN) Tel: +33 (450) 42 81 83 USA Tel: +1 (310) 301-8637 Fax: : +41 (22) 594-85-44 Mobile: (Switzerland): +41 79 595 5468 email: nick.ashton-hart@icann.org Win IM: ashtonhart@hotmail.com / AIM/iSight: nashtonhart@mac.com / Skype: nashtonhart Online Bio: https://www.linkedin.com/in/ashtonhart