These are initial comments of the BC on this draft report, which we acknowledgefiling during the portion of comment period designated for reply comments.While the BC supports a two-part comment period, we are finding that thetime for initial comments should be lengthened.
In addition, we believe that comment periods should be extended wheneveran ICANN public meeting occurs during the comment period. Public meetingsrequire intense participation for several a days, leaving little time toprepare public comments. A simple solution would be to add 7 days to anypublic comment period that includes dates of an ICANN public meeting.