Hi Lars,
As I understand it, the period between Reveal Day and String Confirmation Day is 14 days. The current 90 day Objection period runs from String Confirmation Day, so assuming that not all strings will change in that period, an overview can be conducted to classify strings that may be objectionable or require comment so that the initial review period is actually closer to 104 days from String Confirmation Day. The ALAC has asked for 135 days from String Confirmation Day due to its commitment to review applications on all regional levels. I have the following two comments:
1. PROCEDURAL: If, in the previous IRT meetings discussing this topic, the IRT determined the period should be 90 days after full discussion, then it should be 90 days. However, today's discussion leads me to believe this was not fully decided previously and Justine has noted that the "90" was always in brackets. If staff has reviewed this discussion in the recordings and determined the issue was already decided by the IRT, that is one scenario. If that is not the case, then one would have to conclude that the IRT is deciding this now and that is why you have put it out on the list for discussion. IF THIS IS WRONG, PLEASE ADVISE.
2. SUBSTANTIVE: If the question was not previously decided in a definitive manner, I think it makes sense for the IRT to compromise and respond to the ALAC request with an additional 14 days (not an additional 45 days) so that the Objection period runs 104 days from String Confirmation Day. To me, a small compromise makes sense if the issue was not previously decided. Everyone would then have 118 days TOTAL to review and classify but watching for any changes to strings that occur on String Confirmation Day. (Apologies for any confusion I created when I said we should "give the ALAC" some middle ground solution - of course I meant everyone - not just the ALAC.)
Based on today's recording, I know Jeff and others will oppose this idea, but I don't think it's fair to recite that the ALAC access to the Objection process was "controversial". That isn't relevant because it's clear ALAC does have Objection access under the policy. It's also clear that the regional approval process to which ALAC has committed is more complicated, especially where Objection filing is concerned. If ALAC Leadership proposes Objection filing as to a particular string, it's reasonable to think it would take 14 days to (1) get approval from regional bodies to file and (2) get review of a draft filing from the regional bodies and finalize it.
Anne
Anne Aikman-Scalese
GNSO Councilor
NomCom Non-Voting 2022-2026