Along with the proposed criteria for ALS certification, Nick has proposed a new procedure for processing applications. The procedures can be found at the bottom of https://st.icann.org/alac/index.cgi?lisbon_documents. The current process has been problematic due at least partly because of delays in accepting or rejecting applications. And at least part of that is due to ALAC committee members not acting in a timely manner. The proposed procedures address this in a number of ways that I find problematic. - The procedures rightfully give the three ALAC members from the region and the Regional Secretariat an opportunity to comment on an application from their region (the wording is confusing in that it includes the ALAC members twice). In the past, the rest of the ALAC has put heavy reliance on the opinon from the region. However, the provision ends with "Silence on an application = approval" This is trying to address the problem of ALAC members (and presumably Secretariats in the future) not responding in a timely manner. I find it problematic that the ALAC members, two of whom are selected by the Region, may give a different opinion than the Secretariat. I find it more problematic that if no one in the region (or their reps) are doing their job, it is deemed that they have approved and an application may be accepted inappropriately. - In the past, there have been examples of a Due Diligence (DD) saying that criteria (albeit vaguely defined ones) are met, even when the application says the opposite. The new procedure relies more on DD, and we need to ensure that the process of evaluation by staff is more bullet-proof than before (at least partly by actually formalizing the criteria!). - The proposal calls for approval of an application UNLESS at least 3/4 of the entire ALAC votes No. Assuming that there are at least 12 members on the ALAC at the time, this means that only 4 Yes votes are required to approve, and silence counts as Yes. Stated another way, for a full ALAC of 15, it will take 12 explicit No votes to reject an ALAC. It is quite common for one or more ALAC members to be unavailable or simply unresponsive for any given vote, and under these rules, they are effectively voting Yes. To me, this sounds like for all practical purposes, it will be virtually impossible to reject an ALS application. That makes the ALAC a rubber stamp. Even if there were a case of a region applying their own set of rules to accept "their friends", and even in the face of DD rejecting an application, it will be almost impossible to stop the approval. I am not sure what the proper process should be, but this does not sound like it to me. Alan