RE: [council] Comment deadlines

[Jonathan Weinberg <weinberg@mail.msen.com>]

Caroline --

	I think both views have merit.  On the one hand, the overall comment
period was sufficiently long that I don't think anyone can complain of
being unreasonably rushed.  On the other hand, I really don't think there
would be any negative reaction from the WG if the deadline were delayed for
a few hours, and there might be some negative reaction, from the supporters
of the request, if the deadline is not extended.   (Given that -- for
better or for worse -- a disproportionate number of comments may come in
from the U.S. West Coast, it does seem sort of silly to have a deadline set
at 9am Monday morning for people in that time zone.)  Further, I suspect
that a number of comments may come from people who aren't used to dealing
with international organizations and simply assume, without thinking, that
the deadline is COB in their own time zone -- it seems draconian to exclude
them for a procedural slipup.  So my leaning is to grant the request, on
the theory that in general we should accomodate such requests when it's
harmless to do so.

Jon




At 10:12 AM 1/7/00 -0600, you wrote:
>HELLO, ANY NC'rs OUT THERE?????  Kathy initially brought up this request and
>I and Harald  have commented.  All of our emails are pasted below for your
>convenience.  Can we have other people's insight can we can respond to Mr.
>Menge's request since the Jan 10th deadline is next Tuesday!
> 
>Jonathan, as Chair of WGC, I would also like to get your read on this.
> 
>Mr. Menge, until and unless I get more feedback, I would not assume that
>there will be an extension so you can plan accordingly.
> 
>Caroline G. Chicoine  
> 
> 
>
>[KATHY]>[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.
>
> 
>[CAROLINE] I also agree with eliminating time restrictions from deadlines IN
>THE FUTURE since I
>
>suspect that many people participating in this process regardless of their
>
>background (i.e., not only non-commercial organizations, small businesses
>
>and individuals) have full day jobs that require their participation "after
>
>the business day on their personal time."
>
>I personally have no problem applying such a new rule to the current WGC
>
>deadline. However, I simply wish to note that this deadline has been known
>
>by all WGC members well in advance for quite some time (i.e. this was not
>
>the typical fire drill we saw with WGA) and in fact the deadline was
>
>carefully chosen to extend until Jan. 10th in light of the holiday
>
>interruptions. Also, while such a new rule would be only a minor
>
>"extension" of the deadline, I simply point out that WGC does not take
>
>kindly to delays in the process. I received quite a bit of flack for
>
>requesting an extension of the last WGC deadline since it fell right after
>
>the NSI/DOC/ICANN Agreements were released (my reasoning being there was not
>
>enough time to review the Agreements before the deadline in order to
>
>determine whether they affected our position paper). Therefore, for the
>
>minor additional time it would provide, I simply question whether it is
>
>worth the potential "bad press", especially given that the reason for the
>
>request is not a new development. Food for thought.
>
>Caroline
>
> 
>[HARALD]
>
>Kathryn,
>
>2 disagreements - I agree with the rest:
>
>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 <mailto:Harald.Alvestrand@edb.maxware.no> 
>
> 
>
> 
>
>-----Original Message-----
>From: Eric.Menge@sba.gov [mailto:Eric.Menge@sba.gov]
>Sent: Wednesday, January 05, 2000 5:05 PM
>To: council@dnso.org
>Cc: weinberg@mail.msen.com; bburr@ntia.doc.gov
>Subject: [council] Comment deadlines
>
>
>
>Members of the Names Council, 
>
>I am writing to you to explore the possibility of adjusting the WG-C Interim
>Report Comment Deadline.  Currently, the deadline is set to close on January
>10, 2000, 18:00 CET.  For those parties in the North and South America, this
>places the comment deadline from 09:00 to 12:00, which significantly reduces
>the ability to work on comments on the 10th.  
>
>I would propose that deadline be adjusted to January 10 at 18:00 in the time
>zone that the commenter is in.  This would create a sliding scale on the
>globe and give all commenters full use of January 10 to finish comments.
>Also, it would not pick an arbitrary time zone (like EST or CET) to use for
>the deadline.  A deadline based on the commenters time zone would be a
>particular benefit to small businesses and individuals who often must work
>on these issues in the evening or spaced out during the day in between other
>business.
>
>I would be more than happy to discuss the virtues and flaws of this
>suggestion.  If it is too late to consider this option for this deadline, I
>would recommend that the Names Council consider it for the next deadline.
>
>Eric Menge 
>
>-- 
>Eric Menge 
>Office of Advocacy 
>U.S. Small Business Administration 
>(202) 205-6949; eric.menge@sba.gov 
>www.sba.gov/advo 
>
>
>