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I can imagine a number of ways in which public comment could be suppressed. My first effort, sent via a Verizon address, received no reply. My second, via a Yahoo address got through. Today I have attempted to submit an addtional and new comment and have not yet received a verification email in 45 minutes.
Why should the entity, basically in charge of one of the major operations of the internet, not be able to automatically respond to an email in less than 40 minutes? I don't know. I do know, having looked at their last budget, that ICANN spent > $2.5 million dollars for board members to travel to meetings. Perhaps spending 1% of that travel budget on making their email servers travel a little faster would go a long way towards opening up public comment.
Below here is the comment that I am attempting to make a matter of public record with ICANN. IF you do not see my comment on the ICANN message confirmation board in the next 1/2 I invite you to copy and forward the message, signature and all - should you agree to the statements - retaining the original subject line. Simply add a P.S. confirming that you agree with the above and that you are submitting it due to the fact that the original submission was blocked in some manner.
Here is my comment, subject line first.
No Public Record of "Extensive Consideration and Discussion"
Dears Sirs and Madams:
I am gravely troubled by the apparent absence of a public record of the substance of the justifications for the change of pricing policy.
In the announcement of the public comment period ICANN ostensibly offers assurances that a rational and compelling basis for the proposed changes exist. However, despite a deliberate effort on my part, including searching within the links for meeting minutes, I can find no public record of the comments, considerations, facts or other basis for the change. IF such a record exists it is a serious failue to not link to the record from the comment page. IF such a record has not been made public the it is malfesance to conceal the record of facts and reasons whilst inviting public comment.
How is anyone to muster facts or raise a challenge to the significant change without first having an opportunity to review and examine the alleged factual basis for the proposed changes?
I imagine you could argue that the public might attend meetings but when I see that one member of the board was reimbursed in excess of $7,000.00 to attend a 1 week meeting in Paris I think such an argument would not hold up.
IF there actually is a bona fide intent to gain insight from the public then this is a case of failed intention. You cannot gain meaningful input to policy decisions whilst denying us access to facts, figures, evidence underlying the proposed policy change.
IF there is an actual requirement for meaningful public input then that requirement simply has not been met by the adoption procedure as it stands to date. We, the public, cannot possibly meet the challenge of determining the validity or necessity of the proposed changes to the billing process without access to the subject matter or contents of the record of "extensive consideration and discussion". Indeed, in the face of ICANN's public comments that such "extensive consideration" took place the concommitant absence of access to the record makes the case that ICANN has materially failed to allow public participation.
How can there be public comment to what are essentially secret meetings, discussions and considerations?
Until the full record of the facts, evidence, considerations and discusssion is made public this public comment process is and will continue to be a sham.
If the law or contracts require public comment and participation then the contracts, if adopted, will not stand up to an form of intelligent legal challenge.
I would therefore urge ICANN to reset the clock and to do what ought to have been done in the first place: Make the record and evidence for these dramatic changes available for public consideration or at least make the repository for the record plainly available by a llnk in the body of the page where public comment is invited.
Thank you for your consideration and please take my comments to heart. I am not opposed to reasonable and necessary change. However I am steadfastly against significant policy changes that do not receive a full and fair airing in public and against changes that are not brought to the public's attention in a manner decidedly calculated to evoke the greatest degree of public input.
Jeffrey A. Libert, Esq.
[edited by: Webwork at 10:43 pm (utc) on Aug. 28, 2006]
One reason I was not thinking good regarding the UN is that ICANN has showed total disregard of domain name owners with them favoring the open-ended pricing, agreeing to basically automatic renewals of the registry contracts, and being in bed with the large registries as it appears.
What with the way they have acted and the way they seem to have basically no regard for internet businesses and domain owners interests it seems almost anyone would be better than ICANN.