All, I want to throw in my two cents about the comment period. The comments made during our Montreal meetings, by Jim Prendergast (excerpted below) and on the list this week make sense. Publishing a report to the Community that lays out our recommendations -- the whole picture of what we have developed -- is a strong idea. Such a comprehensive report will go a long in building understanding, respect and support for our work -- and sharing it with the rest of the Community who awaits our results. Such a comment will provide critical underpinnings for Community-wide agreement -- and allow us to move forward more quickly to the next round without delay. Now is the perfect time to bring the Community into our circle - to share our work in its entirety - and the quality of our recommendations for the next and future rounds. Let's share it all -- and learn what the GAC and others want to share in return -- while we are still convened and can work together.. Best, Kathy On 11/15/2019 10:18 AM, Jim Prendergast wrote:

Some specific benefits of a comment period inclusive of draft final recommendations:

Context – Greg Shatan raised a very good point about only putting out pieces of the report and that it doesn’t give the community any sense of context in how they fit into the larger report.  Can someone who is concerned with applicant support really comment on contention resolution without knowing what support mechanisms there are for applicants from underserved regions?  As many in the community have not been following the deliberations of this group, they need the context to understand how everything works together.

Interdependencies – As several people noted, our final report will be a rather complex with lots of interplay between sections.  As such, allowing the community the chance to see how the different pieces fit together will paint a more comprehensive picture of how this effort will ultimately look. Without having the entire document to review, it’s impossible to see the various interdependencies.

Changes vs Status Quo - People will naturally focus on any changes to the 2012 round we propose because those are new and different.  But I think putting entire set of proposed final recommendations, including where we recommend no change (the status quo) is valuable as well in case the Board, GAC or others are expecting a change to something and we decided not to make any.  Helps avoid those surprises.

CCT-RT – This report, and ICANN’s and SubPro’s handling of it, is on just about everyone’s radar and was one of 3 Consensus Advice items in the GAC communique. I realize we are still finalizing our position on this but given the high-profile nature of this report, especially in the context of the DNS abuse discussions, we should be sure that everyone knows what we will be recommending before it is finalized. If there is an expectation by the Board, GAC, Org or the community that we should be doing more, then we need to hear that now and not after the report is finalized.

Completeness check – having the draft final recommendations available for comment will help not only this group, but the Board and Org, spot any potential gaps in our policy making recommendations.  I liken this to having an editor review a draft before it is sent to the publisher.  Are we missing anything?  The ICANN Board and Org do not want to be in the same position as 2012 when they were forced to make policy as part of implementation because there were gaps in the Guidebook and related policies.  To date, no one in the WG has seen the whole picture so it’s important for us to do our own completeness check.

Process – some people have raised an issue with whether the initial report was in fact an initial report according to GNSO guidelines.  By putting all the draft final recommendations out for review, I believe it might satisfy those who have raised this issue.

Mind the GAC - During the session on Sub Pro with the GAC, Swiss GAC representative Jorge Cancio made it clear that GAC wants to see the report before the final recommendations “crystalize.” This comment period could accomplish this. Knowing that the GAC now has a “Focal Group” on Subsequent Rounds will hopefully lead to a more efficient process where we receive feedback that could help us avoid GAC advice further down the road.  I am more confident in the Sub Pro WG’s ability to respond to GAC feedback now in a timely manner than I am with the Board’s ability to deal with GAC advice in a timely manner later.

I’d rather get the bad news now and not later – As with GAC advice, I’d want to get concerns from the Board and Org now and not after this has been sent to them by Council.  We can address any substantive issues now as a group and avoid having the Council reconstitute this group if the Board sends the report back with guidance/Instruction.  When Cherine said that the Board would act quickly once they receive the report from Council, don’t make the mistake of assuming they will quickly approve something.  They could just as easily act quickly and send it back to us.  Then we are really stuck.

New comers – Despite lamentations from the co-chairs to the GNSO council about newcomers not familiarizing themselves with the work of the WG, when people raised Sub Pro issues with the Board either during constituency day or the Public Forum, the response given by the Board was “get involved with Sub Pro.”  Having a broader comment period allows such involvement without necessarily disrupting the pace of the work of the group as a whole.  It also allows those of us who have been working on this the entire time to see a full draft report.  Something we have not seen yet.  The initial report was far from complete and the supplemental was a subset of topics.