FINAL VERSION SUBMITTED (IF RATIFIED)
The final version to be submitted, if the draft is ratified, will be placed here by upon completion of the vote.
FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC
The final draft version to be voted upon by the ALAC will be placed here before the vote is to begin.
Posted by Alan Greenberg: 21 Jan 2021, 02:36 UTC
ALAC Comments on Operational Design Phase Concept Paper v2.0
The ALAC appreciates the opportunity to comment on the ODP Concept Paper v2.0.
The ALAC supports the idea of an Operational Design Phase (ODP) to provide sufficient information to the Board in their decision process on addressing complex PDP recommendations such as those coming from EPDP Phase 2.
The ALAC agrees that the Community Design Feedback Group (DFG) as described in the original concept paper was overkill and would add unneeded complexity and time to an already long process.
However, the concepts that it embodied were extremely important. Specifically:
- Those providing feedback would have specific qualifications related to the subject of the design phase; and
- The group would be charged with proactively seeking and coordinating feedback from their respective groups.
The replacement proposed on the v2.0 paper sadly loses all of this. By replacing the DFG with a (or perhaps multiple as discussed during the webinar) GNSO Council liaison(s):
- we no longer have subject-matter experts involved;
- We no longer may have direct paths to the communities who will be involved in the final product, noting that some of these communities may not be presented on the GNSO.
Looking at the SSAD as an example, the GNSO may be able to represent contracted parties and even some of the potential SSAD users, but there would be a complete lack of representation of communities such as law enforcement and cyber-security experts who will certainly be among the most critical SSAD users.
Looking at upcoming Board decisions on PDP recommendations, we have the Subsequent Procedures PDP and Review of Rights Protection Mechanisms. Both of these will greatly involve people and entities that will not be part of the ICANN community at the time of their respective OPDs.
Without such groups having a clear path to commenting on and influencing the operational design (we are not talking about altering the policy), the chances that the Board will consider and approve a design which will meet all of the multiple communities needs will decrease significantly. And that negates the very purpose for which the ODP was created.
DRAFT SUBMITTED FOR DISCUSSION
The first draft submitted will be placed here before the call for comments begins. The Draft should be preceded by the name of the person submitting the draft and the date/time. If, during the discussion, the draft is revised, the older version(S) should be left in place and the new version along with a header line identifying the drafter and date/time should be placed above the older version(s), separated by a Horizontal Rule (available + Insert More Content control).
ALAC Comments on Operational Design Phase Concept Paper v2.0
The ALAC appreciates the opportunity to comment on the ODP Concept Paper v2.0.
The ALAC supports the idea of an Operational Design Phase (ODP) to provide sufficient information to the Board in their decision process on addressing complex PDP recommendations such as those coming from EPDP Phase 2.
The ALAC agrees that the Community Design Feedback Group (DFG) as described in the original concept paper was overkill and would add unneeded complexity and time to an already long process.
However, the concepts that it embodied were extremely important. Specifically:
- Those providing feedback would have specific qualifications related to the subject of the design phase; and
- The group would be charged with proactively seeking and coordinating feedback from their respective groups.
The replacement proposed on the v2.0 paper sadly loses all of this. By replacing the DFG with a (or perhaps multiple as discussed during the webinar) GNSO Council liaison(s):
- we no longer have subject-matter experts involved;
- We no longer may have direct paths to the communities who will be involved in the final product, noting that some of these communities may not be presented on the GNSO.
Looking at the SSAD as an example, the GNSO may be able to represent contracted parties and even some of the potential SSAD users, but there would be a complete lack of representation of communities such as law enforcement and cyber-security experts who will certainly be among the most critical SSAD users.
Without this groups having a clear path to commenting on and influencing the operational design (we are not talking about altering the policy), the chances that the Board will consider and approve a design which will meet all of the multiple communities needs will decrease significantly. And that negates the very purpose for which the ODP was created.
6 Comments
Hadia Elminiawi
Thanks Alan for the draft. I would like to add the following in relation to the flow chart on the last page of the concept paper.
The flow chart on the last page of the concept paper indicates a direct path of communication between the GNSO council and the ODP team other than the GNSO Council Liaison/Liaisons to the ODP group. More clarification is required in relation to this other means of communication between the ODP team and the GNSO council and if you have some other direct means of communication between the council and the ODP team why do you need a Liaison?
Alan Greenberg
My preference is to not add that for the following reasons:
- it is indeed a valid question, but it is a result of the insertion of the GNSO Liaison into the equation, which is out main point of contention - and why the GNSO Council itself is even the focus.
- I am a bit worried that they may address your point and ignore the main one - it is FAR easier to address than putting back some sort of DFG.
Let's discuss further.
Justine Chew
On Wed, 20 Jan 2021 at 10:50, Justine Chew wrote:
Holly Raiche
I would like to strongly support Hadia's comments. The change in nature from what was originally proposed (as sumarised by Alan) becomes clear in both the text and Hadia's reference to the flow chart. At p. 4, while a 'subject matter expert' is appointed by the CEO, further concultation - 'to involve the wider community' can include (but not must) a dedicated webpage and regular outreach to seek feedback and provide updates. That does not fit the description of what was envisaged.
Yes, the original plan is a bit unwieldy and bureaucratic, but it did ensure more than one subject matter expert was involved and that the group of experts actively engaged their stakeholder groups.
So I support Alan's final paragraph and we should call for a return to having a group of experts (appointed by the CEO appointed subject matter expert) to manage the consultations to address the implementation issues. That group can, and probably will, have membership on that group of experts. And, at the least, maybe even mandate that a GNSO be a member of the group. But, as Hadia points out, why the need for a special GNSO liaison when that was not the point of the original concept.
The other important point made today is that this process will become a model for dealing with complex implementation issues, not just the EPDP, so it must include all relevant subject matter experts, who can then consult with their communities.
Alan Greenberg
Final version posted above adding reference to other PDPs that are coming soon and will be critically impacted by the lack of community input.
Hadia Elminiawi
Alan, I think we would also need to highlight that we expect feedback and clarification in relation to the intent of the policy or the intent of some specific policy recommendations, to come directly from the council as the owner of the policy. However, when it comes to feedback directly related to implementation issues other elements of the community need to be included.