Fellow Councilors:
I want to suggest a potential edit to our Council
letter.
Right now it reads:
We expect that the
CCWG-Accountability develop a Supplemental Proposal based on the input from its
Chartering Organizations and the public, the GNSO Council expects also that it
and other Chartering Organizations, as well as the larger community, will
have an adequate opportunity to review and comment on the Proposal in a timely
fashion.
My suggested revision would have it read as
follows:
We expect that the
CCWG-Accountability develop a Supplemental Proposal based on the input from its
Chartering Organizations and the public, the GNSO Council expects also that it
and other Chartering Organizations, reflecting the larger community, will
have an adequate opportunity to review and comment on the Supplemental
Proposal in a timely fashion. (changes in Bold)
As the sentence notes via its reference “and the public”, we
have already had a public comment period on the Third Proposal. The draft
language could be read to suggest that we favor another round of public comment
on the anticipated Supplemental Proposal, which could prevent NTIA from
receiving the Proposal in the timely manner required (delivery by mid-to-late
February) that provides a substantial likelihood of completing the transition in
2016.
The proposed revision emphasizes that the Chartering
organizations, including the GNSO, are the proper entities to submit any
additional comments on the Supplemental Proposal and can transmit the views of
their constituents.
I realize that some Councilors may wish to have the
Supplemental Proposal subject to another round of public comment. If there is a
consensus for that position then I would suggest that any such comment period be
limited in duration to reflect the fact that the narrow subject of such comments
would be those changes made from the Third draft in response to the recent
comment period.
In any event, I believe our letter should be more clear than
the present draft regarding the Council’s position in regard to whether an
additional round of public – as opposed to Chartering Organization – comment is
desired on the Supplemental Proposal we expect to see shortly.
Best to all,
Philip
Philip
S. Corwin, Founding Principal
Virtualaw
LLC
1155 F
Street, NW
Suite
1050
Washington,
DC 20004
202-559-8597/Direct
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