[council] Re: To Names Council on WG-C Deadline

[Harald Tveit Alvestrand <Harald@Alvestrand.no>]

Kathryn,
2 disagreements - I agree with the rest:

>[3]  Comment Deadlines.  For the submission of comments to WG-C, I see a
>fixed date and time for comments.  This time falls midday in the US East
>Coast day and early in the US West Coast day.  It means that the majority of
>a business day is lost to those who want to submit at the deadline (as many
>do).  It also means that the evening is lost to noncommercial organizations,
>small businesses and individuals, many of whom finalize and submit their
>comments after the business day on their personal time.
>
>     I think we set a bad precedent by imposing a fixed time and deadline for
>comments.  In the physical world, such deadlines make sense:  as regulatory
>agencies accept paper filings and have staffs that go home at 5:30pm.  The
>Names Council has no such physical office, and the comments are being filed
>electronically.  Further, deadlines exclude comments, and that is certainly
>not our goal.

Disagreement one: The main purpose of a deadline is to make sure everyone 
knows when the deadline is, so that they get their work done before that 
time.  For such a requirement, a date AND time is a very Good Thing.

>     In this area of commenting, I would like to hold WIPO up as a good
>precedent. WIPO asked that all comments to its domain name proceeding be
>submitted on a certain day -- no time, just a certain day.  This was a fair
>way to handle the issue:  it allowed each country to have its full day and
>night to complete comments.  If one country gets a few more hours in a day,
>there is no harm.  If one country does not get its full hours in a day, I
>believe there is.

Disagreement two: On a round globe, stating "day only" is equivalent to 
stating "day, <somewhere in the world>, 23:59:59". Someone will always be 
disadvantaged by this - if <somewhere> is the +1200 timezone (the latest 
possible interpretation), Japan and Australia get a full working day *more* 
to complete comments than the US West Coast has, by the same logic.

>
>     So, I formally request that the comments for the WG-C deadline on 
> January
>10 be changed to include a date only, and no time.   This change will make
>the process of comment submission easier for noncommercial groups,
>individuals, and small businesses.

Based on the disagreements above, I request (as an individual; I claim no 
other standing in this case) that the Webpage continue to show a date and 
time (GMT) of last submission on all deadlines it publishes. I have no 
opinion on the best time of day to use.

                              Harald A

--
Harald Tveit Alvestrand, EDB Maxware, Norway
Harald.Alvestrand@edb.maxware.no