Dear ICANN Executive Team:
Earlier this year, the Policy Department was directed by the Board to provide specific action plans to address two specific recommendations of the second Accountability and Transparency Review Team (ATRT2) dealing with Public Comment improvements. As a result of this directive, we have developed a set of enhancements that I summarized in a blog post posted this past summer before the ICANN Public Meeting in London. The program enhancements will officially become effective on 26 January 2015, but we will be starting implementation efforts before that time. Please review the enhancements and process changes identified below and share them with your team members who have or will have Public Comments responsibilities.
I. PROGRAM ENHANCEMENTS:
No. | Brief Description | Rationale/Explanation |
1 | Suspended “Reply Cycles” | A data analysis covering 3 years of Public Comments has not supported the effectiveness of Reply Cycles which were added in January 2012 as a result of recommendations from ATRT1. As noted in the published analysis report, the number of Replies to Public Comments solicitations since implementation averaged less than one; moreover, 70% of all solicitations received no qualified Replies and 18% received only one Reply. Staff’s conclusion was to suspend Reply Cycles effective with this change and follow up in approximately six months to evaluate the effectiveness of this process revision. |
2 | Introduce minimum 40-day comment period default target | Given the elimination of the 21-day Reply Cycle (see #1 above) and responding to the frequently expressed community concern that there is often an insufficient amount of time to produce substantive responses to Public Comments, the new “default” target comments period is lengthened to 40 days. Setting shorter periods is possible with the approval of two ICANN Staff Global leaders. Comment periods longer than 40 days are, of course, acceptable. |
3 | Reinforce clear deadlines for Staff Summary Reports | The deadline for Staff Summary Reports has been 2 weeks since January 2012; however, a new policy requires management escalation if a report is not published within the allotted timeframe and no advanced communication is received requesting a delay due to extenuating circumstances. The ICANN web page for each Public Comment solicitation will prominently depict the status of each proceeding from comment opening to the posting of the Staff Summary Report. |
4 | Implement Staff Summary Report community inquiry protocol | The ATRT2 specifically recommended that, “The Board should establish a process … where [participants] can request changes to the synthesis reports in cases where they believe the staff incorrectly summarized their comment(s).” Working with our IT and development colleagues, Staff has introduced a simplified protocol through which a community member may submit an inquiry, through the Public Comments website, for subsequent review, analysis, and disposition by Staff. |
5 | Introduce release staging of Public Comments solicitations | After a thorough vetting of this idea and much feedback from community members and many staff, we have elected to refrain from introducing any staging effort for the opening of public comment forums. Future comment periods will be initiated through an email submission to public-comments @icann.org and coordinated by public comments staff (see below). |
II. PROCESS IMPROVEMENTS:
In addition to the above four substantive improvements, we are also introducing a few procedural changes which we believe will further enhance the overall process:
To ensure consistency with the new Staff Guidelines (v3.0 attached), all requests to open or modify a Public Comment opportunity must now first be directed to public-comments@icann.org. Our team will work with you to finalize and forward each request to Web-Admin for publication on ICANN.org. Staff departments will continue to be responsible for managing the Public Comments solicitations they initiate as well as producing timely Staff Summary Reports consistent with the Guidelines.
We have updated all the Public Comment templates to conform to the new Guidelines. The templates are available for download on the Community Wiki under the SOAC/E tab, Public Comments Documents & Forms Library. For this latest iteration, templates remain in familiar Microsoft Word format.
We are also working on a process to ensure that all Public Comments will now appear on the ICANN.org master calendar (https://features.icann.org/calendar).
The revised Staff Guidelines (attached) and templates will be effective for all Public Comments opportunities that are initiated on or after January 26, 2015. If a solicitation needs to be opened between now and 26 January, please contact public-comments@icann.org and staff will get back to you immediately.
We have worked with the IT team to make the appropriate revisions to the Public Comment web pages on ICANN.org (effective 26 January 2015) and to ensure a smooth process transition as well.
TRANSITION ISSUES:
In order to ensure a smooth cutover as well as consistency of presentation on the ICANN.org website, the following transitional steps will be followed:
We are using a variety of ways to alert the community to these changes. In addition to my previous blog posts and Policy Update articles, we will be posting informational materials on ICANN.org, the Community Wiki, as well as making presentations to individual ICANN community groups as requested.
The Staff member responsible for any currently open Public Comments solicitation that expires after 26 January 2015 (currently 2) will be contacted individually and asked to modify the Comment Period to reflect these process changes. This change should be accompanied by a community announcement so that those who planned to participate are alerted to the deadline changes.
Any new Public Comments request that is received by Web-Admin on or before 26 January 2015 will be forwarded to the Public Comments Staff to ensure that it conforms to the new procedures (no Reply Cycle) and timeframes (default minimum 40 days Comment Cycle). We understand that some public comment opportunities are mandated by contract and will need to follow different timetables.
We plan to hold two webinars for ICANN staff on 9 January and 16 January to review these changes and to answer any Staff questions that may be raised.
Finally, Rob Hoggarth and Carlos Reyes will be working to establish an advisory committee comprised of Staff content producers to discuss, collaborate, and strategize about improvements to all forms of community input mechanisms including Public Comments. An additional responsibility of this committee will be to evaluate new and innovative ideas that can help us better serve the full range of needs presented by our diverse community participants and customer bases. Please let Rob or Carlos know if you would like to have a member of your team participate in that effort.
This is a good bit to digest right around the holiday period, but the timing will help us be up to speed by the ICANN Public Meeting in Singapore. If you have any comments or suggestions about these Public Comment changes, please let me, Rob or Carlos know.
Regards,
David
David A. Olive
Vice President, Policy Development Support
General Manager, ICANN Regional Headquarters –Istanbul
