In comments submitted on the Applicant Guidebook, MarkMonitor writes:
ICANN has only allotted a 28-day window to the Stakeholder Community to review the considerable revisions to the PF-AG and analyze all of the supporting and ancillary documents posted by ICANN. We acknowledge that in earlier comment periods, ICANN demonstrated more concern and respect for the Community stakeholders who are affected by the proposed introduction of new gTLDs and allocated the following time frames for comments:
DAG 1: October 23 December 15 (53 days)
DAG 2: May 31 July 20 (50 days)
DAG 3: October 4 November 22 (49 days)
DAG 4: May 31 July 21 (51 days)
The revisions to the PF-AG are largely driven by the recent ICANN Board decision to allow Vertical Integration (VI). This decision departed dramatically from the previous versions of the DAG, and the Board's stated position of adopting a more conservative, vertically separated distribution model. If this is the "Final" DAG and it integrates significant change, logic would dictate that ICANN should provide adequate time to the Stakeholders and Community to enable review and development of substantive comments to this critical document. A longer comment period, equaling or exceeding previous periods would be much more prudent, especially considering that the Board and Staff have stated that they will evaluate the quantity of comments in relation to previous periods as a measure of support or lack thereof for the PF-AG .
The time allowed for comments is also constrained by the Cartagena ICANN Meeting which is being held concurrent with the comment period. Many attendees are arriving on December 4nd and leaving on December 10th and would be unable to provide substantive input during this period. Furthermore, many within the Community expect to receive additional information from ICANN at the Meeting that may impact the substance of their comments to the PF-AG. Based on this deadline, it is impractical for attending participants to take the information gathered at the Meeting to their respective constituencies, discuss issues and then incorporate their learning into their comments while meeting ICANN¹s comment deadline.
Finally, the Board is currently scheduled (1) to discuss the PF-AG on December 10th, the day on which the comments are due. It is not possible for Staff to gather and analyze the comments, prepare briefing documents and submit them to the Board in the required time frame. The Board itself requires submission of documents several days before a Board vote on any specific topic. Considering that the public comment period does not end before the Board meeting the Board will not have enough time to review and analyze the comments nor will staff have the time to react to them. Given the significance of its decision, we believe that the ICANN Board must take sufficient time to consider the comments made by the Community to the PF-AG before making decisions about the schedule for implementation of the Guidebook(2).
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