RE: [council] Comment deadlines

["Chicoine, Caroline" <chicoinc@PeperMartin.com>]

I have already sent an email to Jonathan to post the new deadline,   In any
event, this is simply to confirm that the Names Council has granted your
request to change the deadline, and that the new deadline will apply to all
WGC comment submitters.
 
I apologize that we could not get back to you sooner.
 
Caroline

-----Original Message-----
From: Eric.Menge@sba.gov [mailto:Eric.Menge@sba.gov]
Sent: Monday, January 10, 2000 9:42 AM
To: chicoinc@PeperMartin.com; weinberg@mail.msen.com
Cc: council@dnso.org; bburr@ntia.doc.gov
Subject: RE: [council] Comment deadlines



Caroline, 

Although I fully intend to finish my comments by the 18:00 CET deadline, the
proposed clarification would enable me to refine my comments and make a
better submission to WG-C. 

I also fully agree with Jonathan's comments that this would be of even
greater benefit to those commenters in the Pacific Time Zone.

Eric 


-----Original Message----- 
From: Chicoine, Caroline [ mailto:chicoinc@PeperMartin.com
<mailto:chicoinc@PeperMartin.com> ] 
Sent: Monday, January 10, 2000 10:34 AM 
To: 'Jonathan Weinberg'; Chicoine, Caroline 
Cc: council@dnso.org; bburr@ntia.doc.gov; Eric.Menge@sba.gov 
Subject: RE: [council] Comment deadlines 
Importance: High 


Jonathan, from the majority of the responses I received (Kathy, Raul, Philip

you and me) it would appear we are in favor of clarifying that the deadline 
should be the COB in the time zone of the person submitting the comments. 
Of course, given the lateness of this email, I wonder whether Eric and 
Kathy, who made the request (or people they were representing) still need 
more time today.  If not, I would prefer to make this rule prospective and 
not stir the waters unnecessarily. 

Kathy and Eric, can you confirm with Jonathan whether additional time would 
still be helpful and if so, Jonathan please post the clarification 
accordingly. 

Caroline 

-----Original Message----- 
From: Jonathan Weinberg [ mailto:weinberg@mail.msen.com
<mailto:weinberg@mail.msen.com> ] 
Sent: Saturday, January 08, 2000 10:36 PM 
To: Chicoine, Caroline 
Cc: council@dnso.org; bburr@ntia.doc.gov; Eric.Menge@sba.gov 
Subject: RE: [council] Comment deadlines 


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
<mailto:Harald.Alvestrand@edb.maxware.no> > 
> 
> 
> 
> 
> 
>-----Original Message----- 
>From: Eric.Menge@sba.gov [ mailto: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 
> 
> 
>